Tax Planning; Tax Minimization

Topics

February 28, 2025

Tax considerations for foreign investment in US private credit

Foreign investors should carefully analyze tax implications and strategies before investing in the growing U.S. market for nonbank credit.

October 1, 2022

US clients with international tax issues: Five helpful tips

U.S. persons (citizens and permanent residents) whose financial matters extend overseas may face a tax situation that virtually no other country’s nationals do.

August 1, 2021

Court says statutory language precludes substance-over-form analysis

The plain language of the statute allowed taxpayers to shelter income from all tax using a foreign sales
corporation and Roth IRAs.

August 1, 2021

PFIC considerations for non-US SPACs

As SPAC activity has increased, non-U.S.-domiciled
SPACs have become more prevalent and carry major U.S. tax-compliance ramifications due to their potential treatment as a PFIC for U.S. investors.

June 1, 2021

Transfer price adjustments don’t necessarily increase import duty costs

Importers should consider transfer-pricing arrangements in advance, based on the totality of the circumstances, to assess any potential refund of duties on adjusted prices to imported goods.

May 1, 2021

Unintended consequences of foreign branch reporting

Certain U.S. citizens and U.S. residents doing business abroad can have surprising tax reporting obligations as a consequence of the IRS’s revised instructions to Form 8858.

February 1, 2021

Transfer pricing and sales/use tax

This discussion outlines the basics of sales and use tax and transfer pricing, considers how intercompany transfer pricing may unintentionally lead to sales tax exposure, and offers steps to avoid audit assessments and penalties.

December 1, 2020