Global Business & Finance
- Cross-border mergers & acquisitions, joint-ventures, divestitures & reorganizations
- International finance, including cross-border syndicated credit facilities
- Foreign Direct Investment (FDI)
- S. investment overseas
- Consular representation
- Family-based immigration
- I-9 Workplace compliance
- Labor certifications
- Temporary & permanent visas
Our tax attorneys are experienced in international taxation laws and represent domestic and foreign clients in international tax matters. Reflecting the Souths attractiveness to foreign companies looking to start US operations, we advise many companies headquartered in other countries on the form and structure these operations should take for effective tax treatment. Whether your concern is inbound or outbound taxation, we can advise you on the tax treatment of investment incentives, royalties, dividends and interest generated by the operations, and we have working knowledge of the international treaty provisions that restrict many of the options ordinarily available to strictly domestic operations. Where such restrictions affect repatriation of assets, we recommend effective alternatives to minimize the tax burden involved. That includes the use of tax treaties, conduit entities, hybrid entities and domestication of foreign corporations to optimize tax deferral where desired.
Our international tax experience includes:
- Citizenship renouncements, expatriations & the U.S. Exit Tax
- Domestic International Sales Corporations (DISCs) & Foreign Sales Corporations (FSCs)
- Executive & personnel mobility & tax equalization
- Offshore voluntary disclosure initiatives for persons with unreported foreign entities & bank accounts
- Structuring cross-border financial & lending transactions, mergers & acquisitions, joint-ventures & investments
- Tax & corporate inversions
- Transfer pricing rules & regulations
Our tax attorneys work to develop and implement substantive and practical tax advice and strategies for our clients in all of the above areas, while at the same time, assisting our clients in evaluating other business and legal issues involved. We utilize resources from other areas within Burr, such as our business, litigation, financial services, lending, and real estate groups.
In addition to the tax aspects of ongoing operations, we advise domestic and foreign companies on the tax implications of mergers, acquisitions and joint ventures. In non-stock combinations, such as joint ventures with foreign partners, we ensure that the deal is structured to minimize the tax consequences. Where these combinations involve loans and letters of credit, we handle the tax issues that you will face as a borrower in making cross-border payments.
Finally, Burr attorneys use their knowledge of the tax laws to advise domestic and foreign companies on a host of day-to-day issues, including:
- US tax treatment of foreign nationals working in this country
- Tax laws of other countries as they apply to Americans working overseas
- Tax planning for import/export operations, including the law as it applies to warehousing and shipping facilities
- Tax implications of finance subsidiaries, payroll subsidiaries, self-insurance subsidiaries and other offshore corporations
- International estate tax planning and administration.
- Cross-border licensing of US-based & non-US IP
- Filing & protecting patent, trademark & copyrights
Trade & Compliance
- Anti-bribery laws
- Corporate anti-corruption policies
- Export compliance regulations, including EAR, ITAR & OFAC.
- Foreign Corrupt Practices Act (FCPA)
- Global privacy and security including the US/EU Safe Harbor
- UK Bribery Act