International Taxation and Tax Treaties

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Our international client base demands international tax expertise. We advise U.S. corporations in connection with their foreign activities and foreign corporations in connection with their U.S. activities.

Our advice includes structuring acquisitions, dispositions, joint ventures and strategic alliances. Where necessary, we work with local tax advisors (with many of whom we have established relationships) to determine optimal structures.

We are expert in the special tax considerations that apply to U.S. persons holding interests in foreign entities, including the rules applicable to controlled foreign corporations and passive foreign investment companies.

We regularly assist clients in developing and implementing agreements relating to the cross-border sales of tangible and intangible property, and in the sale, licensing and development of intangible property.

We have significant experience advising foreign-based corporations and investors regarding inbound investments in the U.S., including through the establishment of branches or subsidiaries, acquisitions of existing businesses, and through the formation of joint ventures and strategic alliances with U.S.-based corporations and venture capital investments.

U.S. News Best Lawyers® Law Firm of the Year 2016
Litigation – Tax

U.S. News Best Lawyers® Best Law Firms 2017
National: Litigation – Tax (Tier 1)
National: Tax Law (Tier 1)
New York: Litigation – Tax (Tier 1)
New York: Tax Law (Tier 1)
Sacramento: Litigation – Tax (Tier 1)
San Francisco: Litigation – Tax (Tier 1)
San Francisco: Tax Law (Tier 1)
Washington, D.C: Litigation – Tax (Tier 2)
Washington, D.C: Tax Law – (Tier 1)

Chambers USA 2017
National: Tax Controversy
California: Tax
New York: Tax

2013 Tax Practice Group of the Year

Legal 500 US 2019
International: Tax
US Taxes: Financial Products
US Taxes: Contentious
US Taxes: Non-Contentious

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U.S. News – Best Lawyers® Law Firm of the Year 2016
Litigation – Tax
Law Firm of the Year

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