We advise on sophisticated cross-border tax matters where precision and judgment matter. Our practice focuses on structuring international activities for tax efficiency while managing regulatory risk in an increasingly scrutinized global environment.
Cross-border structuring for closely held businesses and private clients
U.S. tax considerations for inbound and outbound investments
Treaty-based planning and controversy
CFC, Subpart F, GILTI/NCTI, FDII and BEAT analysis
Offshore reporting and disclosure strategy (FBAR, FATCA)
Pre-immigration and expatriation planning
Coordination with foreign counsel in multi-jurisdictional matters
