International Taxation

Our international tax practice addresses both foreign activities of U.S. persons and U.S. activities of foreign persons, including treaty analysis, currency translation, and inter-company pricing matters.


For outbound clients we focus on, among other things, deferral strategies, foreign tax credit utilization and the efficient repatriation of earnings. For inbound clients we focus on, among other things, withholding taxes, the existence of a U.S. trade or business or permanent establishment, FIRPTA, residency issues, and branch profits tax matters. We work with local counsel and tax accountants in foreign jurisdictions to achieve effective integrated cross-border solutions for our clients.