International business is no longer just about multi-national corporations. High-growth and middle-market companies are routinely expanding operations and pursuing deals both into and out from the U.S.A.

  • Cross-border mergers & acquisition

  • Special tax-free reorganization issues, including potential inversions

  • Controlled foreign corporations (CFCs), Subpart F income, and global intangible low-taxed income (GILTI)

  • Passive foreign investment companies (PFICs)

  • Effectively connected income (ECI) and tax return obligations

  • Real estate investments and Foreign Investment in Real Property Tax Act (FIRPTA)

  • Foreign Account Tax Compliance Act (FATCA)

  • Representative offices

  • Withholding taxes

  • Immigration and expatriation tax planning for entrepreneurs, investors, and executives

  • Tax treaties

  • Transfer pricing