The new millennium has brought us a whole new world, one without limitations and boundaries.
Many international clients reside or work in the United States who are not U.S. citizens, or individuals who are working outside the United States who are subject to U.S. taxation. Some clients may own or control foreign corporations which conduct business throughout the world.
These clients face complex tax issues including:
- Taxation and withholding of foreign nationals working in the United States
- Taxation and withholding of foreign nationals investing in the United States
- Taxation of U. S. citizens living abroad or investing in foreign countries
- Taxation of professionals working in several states or countries
- Taxation of U. S. shareholders who own controlled foreign corporations
- Foreign sales corporations and interest charge DISC corporations
- Transfer pricing and related party transactions
- Foreign tax credit issues
- Transfers to or from a foreign trust
- Gifts received from a foreign source
Our specialists will review tax and information returns, represent clients in all aspects of federal tax controversies, audits and administrative appeals, write protests, review IRS International Examiner audit reports and request Competent Authority, if warranted.
We'll advise you on the applicability of tax treaties as they relate to your client's specific tax issues, and render advice regarding any tax issue or financial transaction with international aspects or implications.