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U.S. Taxation of Foreign Nationals Working in the U.S., Including Planning Opportunities

As multinational corporations continue to expand their operations globally, they must navigate a complex web of tax regulations and laws. It is essential that they take a comprehensive approach to tax planning and not make decisions solely based on the U.S. tax implications. […]

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Tax Planning for Foreign Investors

Tax Planning for Foreign Investors

With the global economy we live in, it is important for Fund Managers to have an appropriately structured fund if they plan to have foreign investors.  Too often, the fund structure is not tax efficient for the foreign investor.  If the fund is not structured to accommodate foreign investment, why should a foreign investor consider investing in the fund? […]

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Comprehensive Planning to Provide the Most Tax-Efficient Structure

Comprehensive Planning to Provide the Most Tax-Efficient Structure

CFOs and General Counsel of multinational corporations (non-U.S. parent) with operations in the United States face complex tax implications that must be planned for on a global basis and not make decisions solely based on the U.S. tax implications. Too often, the U.S. advisor will ignore the tax implications from other relevant jurisdictions to the financial detriment of the multinational corporation. Through our associated networks and our team, we are able to plan for the tax strategy of the multinational corporation to provide a global framework by continually evaluating the multinational group’s operational and tax position and provide solutions that address key considerations. […]

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Comprehensive Global Tax Planning to Reduce the Global Effective Tax Rate

Comprehensive Global Tax Planning to Reduce the Global Effective Tax Rate

CFOs and General Counsel at U.S. multinational corporations are confronted with complex international tax that requires comprehensive global tax planning to reduce the global effective tax rate. Without a comprehensive strategy that considers not only the tax implications of the country where the transaction occurs, but also analyzing the tax implications back to the U.S., planning strategies may bring little to no actual benefit to the U.S. multinational corporation. Our team proactively plans for the tax strategy of U.S. multinational corporations to provide a global framework by continually evaluating the company’s operational and tax positions and respond with a tax analysis that addresses the key considerations. […]

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Membership Interest for Services and Purchaser’s Tax Liability

Membership Interest for Services and Purchaser’s Tax Liability

The after-tax proceeds of the sale of a business is of the utmost importance to sellers. Too often sellers agree to holdbacks or a reduction in purchase price for alleged tax issues raised by the purchaser during due diligence where the purchaser bears no actual risk. […]

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Comprehensive Approach to Tax Planning for U.S. Multinational Corporations

As multinational corporations continue to expand their operations globally, they must navigate a complex web of tax regulations and laws. It is essential that they take a comprehensive approach to tax planning and not make decisions solely based on the U.S. tax implications. […]

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