We get it: Multinational enterprises and global investors require experienced and sophisticated international tax advice to navigate the labyrinth of authorities governing international commerce, including domestic and foreign tax laws, international tax treaties and the pronouncements of influential NGO’s, such as the OECD and the UN. Moreover, the recent Tax Cuts and Jobs Act enacted the most wide-ranging changes to the U.S. taxation of cross-border income since the Kennedy administration. Advisors can solve these complex and challenging issues with substantial international tax experience to design tax-efficient structures to maximize after-tax profits while ensuring compliance with applicable laws and ethical norms.
Polsinelli’s International Tax practice members have the experience and skills to handle the most complex international tax matters. Our International Tax attorneys have many years of experience representing inbound and outbound clients, including multinational corporations, private equity, venture capital and hedge funds, joint ventures, family offices and high net worth individuals in diverse industries and geographies. We regularly provide advice and opinions on international tax matters and represent clients in IRS exams, appeals and court proceedings.
Specific areas of substantive experience include:
- Cross-border transactional planning
- Cross-border mergers and acquisitions
- International joint ventures
- Supply chain structures
- Offshore fund formation
- Transfer pricing and contemporaneous documentation
- Pre-immigration planning
- Foreign tax credits
- Subpart F and GILTI
- FATCA
- Base erosion and thin capitalization rules
- Export incentives, including FDII and IC-DISC
- Global financing structures
- Foreign investment in real property
- Tax treaties and permanent establishment issues
- Intellectual property planning
- Trading/distribution structures
- U.S./foreign tax audits and controversies