We assist companies and other business entities determine US tax efficient cross-border transactions and holding structures. In doing so we take account of US tax treaties and foreign country taxes where appropriate.
In many cases we also provide the tax result of alternative structures on a comparative basis.
We also review existing corporate group structures for US tax efficiency and US tax compliance.
Specific attention is given to structures combining US and non-US entities especially where one or more of the entities is recognized as taxable or as a pass through in the US but not in the foreign country.
In all cases we provide advice on the implementation and disclosure requirements from the US tax perspective.
Whatever the existing multinational structure or proposed cross-border transaction may be, the chances are that we can assist you on the US tax planning, implementation and compliance side.