Overview

Our clients cover a broad spectrum, from Fortune 500 companies and multinational corporations to tax-exempt organizations and closely held businesses. We counsel them on corporate transactions and financings; tax controversy, advocacy and litigation; legislative and regulatory activities; executive compensation and tax planning; international, federal, state and local taxation; and foundation and exempt organization matters.

Non-U.S. entities rely on us for advice on tax planning opportunities and compliance requirements related to acquiring or investing in U.S. real property, including compliance with the Foreign Investment in Real Property Tax Act. We assist foreign investors in developing tax-efficient strategies for structuring start-up business ventures in the United States. We counsel U.S. entities on controlled foreign corporation, Subpart F and passive foreign investment company matters and advise U.S. companies with insolvent foreign subsidiaries on tax planning opportunities. In addition, we provide guidance to U.S. and foreign entities on withholding tax, permanent establishment, limitations on benefits and other tax treaty issues.

Experience
Representative Experience
  • Advising clients on income tax and Social Security tax issues, with and without income tax treaties or totalization agreements, in numerous employee transfers to and from the United States and between foreign countries, including the United Kingdom, Italy, Switzerland, Belgium, Canada, Mexico, Venezuela and China.
  • Advising a client on the foreign tax implications of an expatriate employee participating in U.S. qualified and non-qualified defined contribution plans while performing services for the company in a host location.
  • Representing a Fortune 200 U.S. multinational on the disposition of a major division with operations in numerous countries.
  • Representing a Fortune 200 U.S. multinational on structuring a European joint venture with a large Asian multinational.
  • Representing a Fortune 200 U.S. multinational on restructuring its Asian operation.
  • Representing an Australian internet company on the sale of its business to a U.S. investment company.
  • Structuring the acquisition of a European travel industry company.
  • Advising a publicly held European health industry company on structuring its acquisitions of U.S. health companies.
  • Representing a U.S. telecommunications company in expanding its business to Puerto Rico.
  • Advising foreign investors in a going-private transaction on structuring the acquisition of a U.S. travel industry company.