Our attorneys have assisted domestic and foreign corporations in U.S. and cross-border tax planning matters, including the development of treaty-driven structures designed to mitigate U.S. and foreign tax in international sales, lending and investment activities. We regularly advise foreign clients on the tax considerations of doing business with U.S. companies and on the establishment of branch offices, subsidiaries and agency arrangements in the United States. We also advise corporate clients on the tax implications of intercompany transactions, including transfer-pricing issues, and can advise on the development of transfer pricing methodologies and the negotiation of transfer pricing agreements with the U.S. Internal Revenue Service.
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