We advise domestic and international businesses and private clients on U.S. federal, state and local tax issues, including under applicable international tax treaties. We pride ourselves on collaboratively providing the right level of tax advice for differently situated clients, and we primarily focus on clients’ business goals to provide efficient tax advice. The breadth of our practice affords us a unique perspective at each possible stage of our advice, from structuring and implementing tax efficient structures to ongoing compliance, and also in the event of audits or controversy.
Tax Planning and Structuring
We help plan and structure corporate and commercial transactions, such as investments in U.S. companies, including mergers & acquisitions, the purchase or sale of U.S. businesses, securities or assets, the structuring of U.S. subsidiaries, and licensing and other arrangements (including transfer pricing). We also manage collateral tax issues associated with these transactions, such as foreign tax credits, withholding, and the tax implications of employment arrangements and compensation plans. We work with a network of trusted certified public accountants and other multilingual domestic and foreign tax advisors, experienced in international matters, to implement tax solutions.
Doing business in the U.S. requires particular attention to the complexity of U.S. tax law, which is difficult to efficiently manage without dedicated expertise. Therefore, non-U.S. businesses retain us to act as their outsourced U.S. tax department.
We provide non-U.S. financial institutions and investment funds with comprehensive plans for compliance with the Foreign Account Tax Compliance Act (FATCA) and advise on the day-to-day operation of FATCA compliance programs.
Tax Audits and Controversy, Voluntary Disclosure
We also advise in tax investigations and controversies with the Internal Revenue Service. Our range of experience allows us to represent a variety of taxpayers including business entities and individuals under audit, the appeal of audit results, and litigation in trial or appellate courts.
Our tax controversy practice also extends to advising on the feasibility and management of participation in the U.S. offshore voluntary disclosure program, concerning previously undeclared foreign accounts. Depending on the nature of the matter and a client’s preference, we either lead negotiations with the IRS or we act as advisors with no direct contact with the IRS.