International Tax Planning

U.S. taxpayers with overseas assets and financial interests frequently pay far more U.S. and foreign taxes than legally required – taxes that could easily have been avoided with advice from a lawyer with experience in international tax planning. At the tax law firm of Moskowitz, LLP, we carefully advise business entities and individuals on how to create the most suitable global tax plans for both outbound and inbound investments.

Outbound planning

We use our knowledge and experience of national tax systems and international double tax treaties to help U.S. companies minimize taxes on their overseas transactions.

Cross-border tax arbitrage

We can help you use the inconsistent treatment of international business transactions in separate tax systems to legally obtain tax benefits.

Repatriating foreign profits

We advise our clients in regards to the most efficient manner to repatriate foreign profits back to the United States.

Passive foreign investments

Without proper planning, the Internal Revenue Code’s passive foreign investment company (PFIC) provisions can literally eat away at your entire foreign investment. We can help you minimize U.S. taxes on passive foreign investments such as foreign securities and real estate rental activities.

Foreign gifts and inheritances

If you are a U.S. Citizen or resident, you must report not only your foreign income but also gifts and bequests exceeding $100,000 from a nonresident alien or foreign estate, and gifts of $15,671 or more from a foreign corporation or partnership. Failure to report gifts and bequests on Form 3520 may result in penalties (the greater of $10,000 or 35% of the gross value of the amount received, plus additional amounts for continued noncompliance).

Residency rules and sourcing

Non-resident aliens are taxed under an entirely separate tax regime than from the one that applies to U.S. citizens and resident aliens. Their income is categorized either as effectively or not effectively connected with a U.S. trade or business, and each category is subject to U.S. tax under a different set of rules with which we are intimately familiar. We also assist individuals with income sourcing issues and offer extensive pre-immigration tax planning services. Through this planning, we will help you reduce or eliminate taxes before you become subject to the American tax laws.

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