Our international tax practice is geared to assisting our clients in the planning and structuring of tax efficient cross border transactions, as well as optimally resolving international tax-related controversies. Our lawyers have extensive experience in, among other things, matters involving tax treaties, intercompany pricing, Competent Authority, Advance Pricing Agreements, foreign tax credits, sourcing of income, controlled foreign corporations, in-bound and out-bound investments and transfers of property, branch interest/profit tax and permanent establishments. 

Representative Matters: 

• Structured an international joint venture operation for importing goods and services into the United States
• Drafted and implemented a cost sharing arrangement between U.S.- and foreign-based related corporations for the research and development of intangibles
• Structured, set up and advised captive insurance companies
• Opined on the international tax consequences of real estate activities both within and outside the United States
• Obtained a Competent Authority relief from double taxation for a U.S.-based multinational corporation
• Structured the sale and distribution operations in the United States of a foreign-based electronic manufacturer
• Structured a cross-border financing arrangement between U.S.- and foreign-based related corporations
• Tested the pricing of certain intercompany transactions and confirmed the arm's length nature of such pricing in accordance with the transfer pricing methodologies articulated in the Advance Pricing Agreement entered into between our client and the Internal Revenue Service