• Tax Services for foreign-owned U.S. companies and non-resident investors
• Advice on structuring U.S. investments, considering all alternative U.S. business forms ranging from start-ups to the acquisition of large U.S. target companies
• Choice of business form for doing business in the United States
• Assessment of exposure to a U.S. “permanent establishment”
• Review and analysis of foreign country taxation of U.S. investments
• Financing U.S. investments, including advice with respect to capitalization, limitations on deductible interest expense, “conduit financing” arrangements and related matters
• Advice with respect to intercompany transactions
• Tax Treaty planning and “entitlement” to treaties (“limitation on benefits”)
• Tax aspects of U.S. real estate acquisitions and dispositions (“FIRPTA”)
• Tax planning for high-net-worth international clients with U.S. assets and advice with respect to residency
• Analysis of new U.S. tax legislation
• U.S. Customs Services, trade issues and advice regarding “first sale” planning.