International Tax

Strasburger regularly deals with international tax matters of many types, including structuring inbound and outbound business and real estate investments; cross-border mergers, acquisitions and joint ventures; reorganizing and restructuring multinational corporate groups; handling international tax controversies before the IRS and in the courts; advising on information reporting; and devising specialized planning involving transfer pricing, foreign entity classification, foreign tax credits, foreign currency transactions, profit repatriations, tax treaty issues and reducing or eliminating U.S. estate and gift tax liability.

INBOUND DIRECT INVESTMENT

Strasburger has handled many types of direct investment into the U.S. from throughout the world. We have developed a wide variety of structures for investing in U.S. businesses and real estate, and we seek to minimize worldwide taxes throughout the investment cycle of acquisition, repatriation of profits and on disposition.

Our tax attorneys have advised a wide variety of foreign investors, including foreign based multinational, individual and family groups, foreign governments and other entities. We have formed acquisition and venture capital funds for our clients involving foreign investors and U.S. investment activities, and have structured international joint ventures in a variety of U.S. industries.

OUTBOUND DIRECT INVESTMENT

Our tax attorneys regularly assist multinational clients in developing approaches to maximizing credits against U.S. tax for foreign taxes paid, to facilitate repatriation of foreign earnings on a tax-efficient basis, and to minimize worldwide taxes through restructurings, adjustments to financing arrangements, use of hybrid entities and securities and other methods. Our tax attorneys have been involved in all phases of acquisition, reorganization, disposition and financing activities involving foreign subsidiary corporations and joint ventures abroad. We have also been involved in major acquisitions and dispositions by U.S. multinationals and in implementing international licensing arrangements, addressing the specialized tax issues that arise in such transactions.

REPRESENTATIVE INTERNATIONAL TRANSACTIONS

• Structured offshore start-up venture, involving subpart F issues and estate planning.
• Advised regarding the structuring and drafting of intercompany licensing and service agreements between U.S. parent entity and Mexican subsidiaries.
• Represented U.S. parent company regarding the acquisition of stock and assets of Mexican businesses, including structuring and planning issues and coordination with foreign tax advisors.
• Advised regarding tax planning for compensation of foreign employees of U.S. companies.
• Advised client regarding the U.S. tax treatment of foreign CLOs.
• Represented client regarding the existence of permanent establishments under various income tax treaties.
• Represented client regarding the withholding analysis on various types of payments by foreign businesses made to U.S. companies.
• Advised regarding the withholding and reporting requirements for payments for services made by a U.S. business to foreign vendors.
• Advised client on tax, reporting and withholding issues for drivers engaged in US – Mexico transportation.
• Represented client in tax planning regarding residency issues, reporting requirements and procedures for U.S. citizens moving abroad and aliens immigrating to the U.S.
• Advised regarding the U.S. income and estate tax planning for U.S. investment by Mexican nationals.
  Represented client on tax structuring of U.S. division of Trinidad and Tobago shipping company.

INTERNATIONAL TAX TEAM

James R. Browne Team Leader

Daniel L. Butcher

Farley P. Katz

Crawford Moorefield

  
     
TAXES, ESTATE PLANNING & EMPLOYEE BENEFITS
OVERVIEW OF PRACTICE AREAS

DISCLAIMER © STRASBURGER & PRICE, LLP
All Rights Reserved