In our tax practice, we specialize in U.S. federal, state, and international taxation for mid-sized and multi-national companies, institutional investors and high net worth individuals with a particular emphasis on cross-border issues. Our expertise extends to the representation of clients in federal and state tax controversies and voluntary disclosure proceedings.
We have significant experience in all aspects of tax planning for foreign and domestic investors, including structuring investments and transactions, on both the federal and state level. We regularly advise foreign companies and investors that invest or do business in the United States directly or through intermediaries, branches or subsidiaries. Our international tax planning expertise encompasses advice on the availability of income tax treaties for companies and individuals, avoiding the establishment of a U.S. trade or business or “permanent establishment,” and the availability of reduced U.S. withholding taxes under the portfolio interest exemption, or for dividends, interest, or royalties under applicable income tax treaties.
We also advise public and private charitable organizations in a wide range of matters, including securing tax-exempt status, selecting tax-efficient structures, establishing entities for cross-border fund-raising, and developing and negotiating donor agreements.
In our tax practice we provide the following services, among others:
- International tax compliance, including FATCA compliance, and participation in Overseas Voluntary Disclosure Programs,
- Structuring of transactions and investments to avoid taxation of income effectively connected with a U.S. trade or business (ECI),
- Optimizing the tax efficiency of hedge funds, private equity funds, and real estate funds,
- Creating tax efficient transaction structures for mergers, acquisitions, and divestitures,
- Advice on tax implications of hybrid structures,
- Executive and employee transfer issues,
- Developing repatriation strategies,
- Creating tax efficient international technology licenses, and transfers of intellectual property,
- Advice on tax matters related to joint ventures, partnerships, and limited liability companies,
- Creating tax efficient structures for real estate investments, and advice on tax implications for foreign real estate investors, including FIRPTA, and
- Advice on the circumstances for “nexus” (taxable presence) under state income and sales tax laws.