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 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.

With experience handling international tax transactions in Washington, D.C., Polsinelli’s 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 our International Tax practice 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. Polsinelli’s International Tax attorneys have 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 experience 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

  • Provided international tax advice for a leading food and beverage consumer products company on a $2 billion acquisition of a foreign company.
  • Assisted and advised on restructuring of European and South American operations regarding the manufacture and distribution of key products.
  • Provided advice to a leading clothing retailer on establishment of international operations and negotiation of an Advance Pricing Agreement with the IRS.
  • Handled Competent Authority negotiations for a leading beverage products company on transfer pricing issues.
eAlerts Alerts
The IRS reopened the offshore voluntary disclosure program for taxpayers with unreported foreign accounts and/or unreported foreign income.  Taxpayers participating in the program may avoid criminal prosecution and resolve all outstanding offshore tax issues on a much more favorable basis than that afforded by the IRS on audit.
January 17, 2012