Tax Consulting

Choice of Entity Planning

Acquisition and Divestiture planning

• Taxable and tax-deferred

Qualified Stock Purchases

Inbound U.S. international tax 

• US effectively connected income analysis

• Foreign Investment in US Real Property Tax Act

• FDAP withholding review

• Investment structuring

Outbound U.S. international tax

• Investment structuring

• Section 367 

• Deduction for Foreign-Derived Intangible Income

• Subpart F income

• Net Controlled Foreign Corporation Tested Income

• Foreign Tax Credit Optimization

• Section 962 elections

Tax Treaty Analysis

Value chain structuring including for:

• SaaS providers

• Manufacturers

Tax modeling

PFIC planning

Foreign currency gain/loss

FBAR issues

Section 962 elections

Employer Identification Numbers

Individual tax 

Application for ITIN (Form W-7)