Global Tax Services for U.S. Parent Companies
- Advice on the U.S. tax aspects of alternative forms for doing business abroad and choice of business form
- Structuring cross-border mergers and acquisitions and joint ventures
- Advice with respect to intercompany transactions
- Advice with regard to financing foreign subsidiaries, including assistance in determining the best mix of debt, equity and "hybrid" instruments
- Advice with regard to "passthrough" entities and "checking the box" on foreign entities
- Strategies for minimizing the worldwide effective tax rate and increasing earnings after tax
- Advice with respect to the tax aspects of the ownership and licensing of trademarks, patents and other intangibles
- Advice regarding the accumulation of profits in foreign jurisdictions, as well as the tax cost (and opportunities) associated with repatriating the earnings to the United States
- Alternative locations for foreign investment-tax and non-tax business considerations
- Analysis of proposed changes to international tax laws
- E-commerce-global tax advice
