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International Transactions

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.

  • Assistance to U.S. citizens with probate issues, including obtaining inheritances in Switzerland, Italy, and France.
  • Representation of Swiss citizens with U.S. tax issues, including non-declared accounts.
  • Advice on cross-border trust and estate planning for dual U.S. and Swiss citizens.
  • Advice for non-U.S. persons with respect to U.S. tax issues, including gift tax issues.
  • Advice to expatriates regarding U.S. tax issues, including tax return filing, foreign bank account reporting, and other U.S. tax compliance issues.
  • Assistance to U.S. citizens with Swiss accounts seeking assistance with IRS Voluntary Disclosure Programs.