The globalization of business has resulted in a need for experienced international tax advice. With the labyrinth of United States and foreign tax laws and international tax treaties, you need advisors with substantive experience who can point out international tax issues and configure your international operations to maximize your business and thus, remain competitive in the global marketplace.
Polsinelli Shughart PC International Tax attorneys have developed that experience by assessing United States and foreign-based multinational corporations, joint ventures, and individuals in the design and implementation of tax efficient global finance, intellectual property, trading/distribution structures, and U.S./foreign tax audits and controversies.
A former special counsel to the associate chief counsel (International) of the Internal Revenue Service leads our international tax group. With over a decade of experience handling international tax transactions in Washington, D.C., the international tax team has the in-depth knowledge and skills to handle the most complex international tax matters. Our long-standing relationship with the Internal Revenue Service and the U.S. Treasury Department provides a distinct advantage to our clients.
Members of the international tax group have represented clients in U.S. tax cases before the IRS Office of Appeals, the IRS National Office, the Tax Court, the federal District Courts and the U.S. Courts of Appeals. The international tax group has also represented clients in Competent Authority negotiations and Advance Pricing Agreement matters.
Multiple tax burdens compromise competition and deplete resources, and developing and defending an effective international tax structure is one way our attorneys preemptively address international tax challenges. Specific areas of substantive expertise include:
- Subpart F planning
- Cross border transactional planning and structuring
- Mergers and acquisitions (domestic and international)
- Joint venture structuring
- Entity classification
- Check the box planning
- Tax minimization strategies
- Foreign tax credit planning
- Dual consolidated loss planning
- Transfer pricing
- Electronic commerce issues