We provide representation and counseling in connection with:
- Advance pricing arrangements
- Competent authority requests
- Controlled Foreign Corporation (CFC) counseling
- Expatriate tax package development
- Foreign tax credit counseling and planning
- Foreign tax law and regulation counseling
- Foreign tax reporting obligation counseling
- IRS reporting obligation counseling
- Passive foreign investment company counseling
- Sub-Part F income counseling
- Tax incentive programs for international investment counseling and international trade counseling (formerly FSC counseling and extra-territorial income counseling)
- Tax minimization in establishing foreign operations in ongoing international business operations and in liquidating international business operations
- Tax planning for international business operations and transactions, international investments, mergers and acquisitions and joint ventures
- Tax treaty applications and planning
- Transfer pricing arrangements, audit preparation and representation
- Value added tax planning and counseling
- Withholding tax counseling and minimization