Cross-Border Taxation Services

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