Our Tax Group has extensive experience in structuring tax-efficient structures for non-U.S. companies expanding into the United States and U.S. companies operating globally.
We have a deep track record in analyzing U.S. income tax treaties and in structuring a company’s operations to maximize treaty benefits and achieve reduced withholding and branch profit taxes. Our experience includes helping companies contend with the impact of the Controlled Foreign Corporation and the Passive Foreign Investment Company rules.