Cross-border operations and expansion, including the flows of capital, people, services, goods and intellectual property, are infinitely complex

Our professionals help multinational companies minimize their current worldwide tax burden on business operations and implement tax-efficient operating structures for the future. We have over 25 years of experience in addressing complex international tax issues.  

Whether your company is expanding inside or outside the United States for the first time or a company looking to restructure its international operating model, we have the experience in key areas of international tax including: intercompany transfer pricing; mergers & acquisitions and reorganizations in a multi-national context; earnings and profits studies; and inpatriate and expatriate tax services.  Your international tax engagement team has extensive knowledge in the area of cross-border tax issues and will be available to answer your questions, as well as discuss tax-saving opportunities with you.  

Increased cash flows. Reduced effective tax rates. Effective entity structuring.  Efficient allocation of income and costs. These are just a few of the advantages that we help multinational companies achieve. Our clients benefit from innovative solutions and practices, realizing substantial gains in efficiency, value-added results, and improved processes and methodologies.

U.S. inbound tax services

For foreign companies and U.S. non-residents looking to invest or do business in the United States, we can help with:

  • determining whether activities in the United States create a taxable presence, including under any applicable income tax treaty

  • structuring the holdings of U.S. investments or acquisitions, including M&A services

  • tax-efficient financing of U.S. operations or acquisitions

  • Minimizing U.S. withholding tax

  • U.S. tax compliance

U.S. outbound tax services

For U.S. companies expanding abroad, we can help with:

  • Taxation of foreign profits before repatriation to the United States, including Subpart F income and GILTI

  • Maximizing the tax benefits under the foreign derived intangible income (FDII) regime

  • Acquisitions and divestitures abroad

  • Corporate reorganizations

  • Dividends and repatriation

  • IP planning

  • U.S. and foreign tax compliance

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