There is a tax consequence for every business decision you make and transaction your company conducts. And you have an almost endless variety of options regarding how you deal with international tax and regulations.
Our International Tax team is a unique breed. Accountants and lawyers – we take a high-level, strategic approach to business and taxes, looking at every challenge from multiple perspectives. We consider all aspects of the issues, then bring to bear whatever of our International Tax services are needed to deliver the right solution.
For our corporate clients, we focus on a wide range of inbound and outbound taxation issues relating to business operations conducted in the U.S. and abroad. This group's principal areas of focus are the effective structure of international and domestic transactions, offshore investment activities, and repatriation programs to minimize the U.S. and foreign income taxes of our U.S.-based multi-national clients.
We have experience in all areas of international tax, including:
· strategic planning such as choice of country and/or legal entity;
· licensing and maximizing after-tax royalty income;
· taking advantage of export tax incentives;
· joint ventures with foreign partners;
· financing foreign operations;
· assessing the tax impact of currency fluctuations;
· exchange controls and repatriation of capital and profits;
· using treaties to mitigate tax costs of cross-border transactions;
· mergers, acquisitions and reorganizations in a multinational context;
· foreign tax credit planning;
· foreign countries' tax and other incentives;
· inpatriate and expatriate tax services for employees;
· compliance with tax laws and regulations;
· identifying tax opportunities and risks, developing strategies;
· intercompany transfer pricing;
For our individual clients of high net worth, we offer the following services:
I NTERNATIONAL TRANSFER TAX PLANNING
estate planning with non-US citizen spouses
planning for foreign nationals investing in the US
life insurance planning
FOREIGN TRUSTS
pre-immigration trusts for non-resident aliens
structuring distributions from foreign trusts to US beneficiaries
asset protection trusts
US INVESTMENTS BY NON-RESIDENT ALIENS AND NON-US FAMILIES
investing in US real estate
investing through non-US entities into the US
investing in venture capital
INTERNATIONAL EXECUTIVES
expatriation from the US planning, i.e., relinquishing green card or citizenship
exit/departure planning from the US
FOREIGN INVESTMENT BY US PERSONS
analysis of foreign investments held by US persons to identify applicability of anti-deferral rules
COMPLIANCE
foreign partnership compliance and reporting
foreign trust compliance and reporting
transfers to, and interests in, foreign entities
conversion and translation of foreign accounts to US tax principles
Additionally, due to the key geographic position of Miami, Florida in relation to the Caribbean and Latin America, and our diverse group of professionals, the International Tax team has vast knowledge and experience in effective tax structuring and planning of multi-national clients in the Caribbean and Latin American region. Likewise, the International Tax team regularly monitors proposed legislation and regulatory international tax developments throughout the world, but especially throughout the Caribbean and Latin America, to assists our clients on a wide range of international tax matters.
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