TAX SERVICES FOR FOREIGN-OWNED U.S. COMPANIES AND NON-RESIDENT INVESTORS

  • Tax Services for foreign-owned U.S. companies and non-resident investors
  • Advice on structuring U.S. investments, considering all alternative U.S. business forms ranging from start-ups to the acquisition of large U.S. target companies
  • Choice of business form for doing business in the United States
  • Assessment of exposure to a U.S. “permanent establishment”
  • Review and analysis of foreign country taxation of U.S. investments
  • Financing U.S. investments, including advice with respect to capitalization, limitations on deductible interest expense, “conduit financing” arrangements and related matters
  • Advice with respect to intercompany transactions
  • Tax Treaty planning and “entitlement” to treaties (“limitation on benefits”)
  • Tax aspects of U.S. real estate acquisitions and dispositions (“FIRPTA”)
  • Tax planning for high-net-worth international clients with U.S. assets and advice with respect to residency
  • Analysis of legislative proposals
  • U.S. Customs Services and advice regarding “first sale” to minimize U.S. import duties