Business Planning, Joint Venture Agreements, Incorporating and establishing a Limited Liability Company or Corporation, Buying a Business, Registering Trademarks and Copyrights, Marketing/Website Compliance, Commercial Leasing, Financing & Funding, etc.) to operation (Licensing Agreements, Distributorship Agreement, Executive Contracts, Employer Compliance, Sales and Service Agreements, Contracts, etc.) and through business exit strategies (Business Sale, Merger or other Disposition).
“in-bound” transactions including the treatment of non-resident aliens and foreign corporations investing and/or doing business in the united States, as well as “out-bound” transactions the treatment of US citizens and residents investing and/or doing business outside the US.
Business and investment transactions by nonresident alien individuals and foreign corporations earning income in the US (inbound transaction) including residence for income taxation, sources of income, sources and allocation of deductions, US taxation of passive income by nonresident aliens and foreign corporations, the branch profit tax and gains of foreign taxpayers from the sale of US Real Property
US taxation of foreign operations by US individuals and corporations including an in-depth analysis of the foreign tax credit, controlled foreign corporations, passive foreign investment companies, foreign sales corporations, and foreign currency transactions
Analysis and advice concerning the role, function and uses of income tax treaties. General aspects of treaties (policy, legal authority and negotiation), the interpretation of treaties, and examination of the terms of the US Model Income Tax Convention, the OECD Model Tax Convention, the United Nations Model Double Tax Convention between Developed and Developing Countries, as well as selected provisions of current United States treaties in force.
◾taxation of investment income (i.e. interest, dividends and capital gains),
◾taxation of license fees and royalties, treaty shopping;
◾limitation of benefits, permanent establishment;
◾taxation of the income of natural persons (i.e. personal services), allocation of income between related parties, non-discrimination toward foreigners and recent treaty developments
US tax issues relating to both inbound and outbound mergers, acquisitions and joint ventures, including taxable acquisitions and dispositions, joint ventures, tax-free acquisitive exchanges and reorganizations, and distributions and divisive reorganizations.
International wealth and income tax planning for high-net-worth and high-income individuals. In particular, the two paradigms: 1) a US citizen or resident who invests overseas or moves overseas to live or work; and 2) a non-resident alien who invests in or moves to the United States. US tax treatment of grantors, trustees and beneficiaries of foreign trusts and the special tax treatment of US citizens who renounce US citizenship, and resident aliens who surrender their permanent residence visa (green card). Special reporting of foreign financial assets required by US persons, and withholding documentation required by withholding agents before making payments to foreign persons.