| International Practice
We offer sophisticated planning to business and individuals with international circumstances. We structure U.S. investments and operations for foreign individuals and entities. We structure foreign investments and operations for U.S. individuals and entities. We advise individuals with dual citizenship and dual residency issues.
- Investment in the U.S.
We assist nonresident alien individuals, resident noncitizens, foreign corporations and foreign trusts with respect to structuring, holding and operating investments and businesses in the United States.
- Operating Businesses in the U.S.
We will advise with respect to U.S. permanent establishemnts, branches, subsidiaries, branch profits taxation, withholding, and regulatory issues associated with foreign ownership of U.S. businesses.
- International Treaties
We have expertise in international incopme tax treaties and estate tax treaties.
- Investment Abroad
We advise U.S. citizens, noncitizen U.S. residents and U.S. companies with respect to investment in other countries and with respect to the operation of businesses in other countries.
- Cross Border Financing
We will assist in documenting and structuring cross border loans, equity investments, hybrid and conduit transactions.
- Operating Business Abroad
We will advise regarding the regulatory and tax issues associated with the operation of businesses in jurisdictions around the world.
- Residency Issues
We advise regarding U.S. residency status and the issues relating to establishing and relinquishing U.S. residency.
- Estate Taxes for Non U.S. Persons
We have expertise in the area of the application of the estate and gift tax rules to nonresident alien individuals, resident noncitizens, and noncitizens married to U.S. citizens.
- Estate Taxes regarding Property with foreign situs
We will assist in estate planning to minimize liability for estate taxes in the U.S. and in other jurisdictions with respect to foreign situs property.
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