U.S. Taxation of Multinational Corporations

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 and are happy to coordinate that advice if that’s what the client wants.

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. (This comes in very handy when floating a foreign corporation’s stock in the United States.)

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. In fact, one of our partners teaches a law school class on intellectual 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.