Ensuring that your business is in compliance with tax reporting requirements and statutory filings is no easy task, especially if you are operating in multiple jurisdictions.
The international corporate tax attorneys at Moskowitz, LLP help both domestic and foreign companies stay abreast of local laws and regulatory issues, and provide comprehensive strategies that are responsive to new legislative developments.
We help domestic corporations reduce U.S. and foreign tax on their foreign source income through a variety of tax reduction techniques.
Inbound tax planning
We assist foreign corporations that generate income in the U.S. with their U.S. tax withholding, branch profits tax, transfer pricing, earnings stripping, and other cross-border tax issues.
Cross-border financing arrangements
We can assist your company to evaluate the most tax-efficient manner of financing your overseas business activities.
With a corporate inversion, you re-incorporate in a country with a lower tax rate. Your company will no longer need to pay U.S. tax on its worldwide income.
Check-the-box regulations facilitate the creation of “hybrid” entities that are treated as separately taxable corporations under foreign law but as flow-through entities that are disregarded for U.S. tax purposes.
Income tax treaties
Our knowledge of national tax systems and international income tax treaties can protect a business’ international activities from double taxation.
Subpart F planning
Under 26 USC Part III, Subpart F, certain types of controlled foreign corporation (CFC) income must be included in U.S. shareholders gross income, even if the income has not yet been distributed. These extremely complex rules mandate proper planning by an experienced international tax lawyer.
Entity formation in jurisdictions outside the U.S.
We understand the legal and tax consequences of entity formation in jurisdictions outside the U.S. and have helped many of our clients establish and operate offshore entities in a number of different jurisdictions.
Sometimes parent companies need access to the after-tax earnings of a foreign subsidiary. With proper planning, double taxation can be avoided.