International Business Tax Lawyers

Assisted a major Australian food and beverage distributor in structuring its U.S. operations in a tax-efficient manner.
Provided tax advice to a major European-based consumer products conglomerate in its acquisition of several U.S. businesses and its integration of those businesses into its pre-existing U.S. business operations.
Structured the acquisition of a U.S. distribution business by a German manufacturing corporation as a tax-free reorganization.
Assisted a U.K. industrial lighting company establish a U.S. distribution subsidiary and helped structure the intercompany transactions and arrangements between the companies in a manner that facilitated their transfer pricing goals consistent with the company’s preferred business model.
Evaluated the likely eligibility of dividends paid by U.S. subsidiaries of a large foreign-based multinational enterprise to an intermediate Swiss holding company for reduced U.S. income tax withholding under the U.S.-Switzerland income tax treaty.
Assisted a U.S. pharmaceutical company in meeting its transfer pricing documentation and compliance obligations with respect to its U.K. affiliate.
Advised several mid-sized U.S.-based multinational businesses on ways to minimize the extent and impact of GILTI and subpart F inclusions from their foreign subsidiaries.
Significant experience in competent authority proceedings between the United States and its treaty partners in resolving transfer pricing disputes, in determining the eligibility of cross-border income items for treaty relief, and in ensuring that taxpayers were in fact eligible treaty country residents.
Represented several corporations with more than $25 million at issue, contending that the gain they realized from the sale of a limited liability corporation or as the result of an election under Section 338 of the Internal Revenue Code was not subject to Pennsylvania state corporate net income tax.
On behalf of one of the largest banks in the United States, obtained an abatement of IRS penalties arising from the late filing of a foreign national's federal estate tax return.
Helped structure the worldwide operations of a group that specialized in the development, manufacturing and licensing of food supplements to minimize U.S. and worldwide tax.
Defended a foreign trust administered in Guernsey, Channel Islands, against a proposed 35 percent IRS penalty for the late filing of a form.
Structured the U.S. operations of a European-based fabric manufacturer and distributor to minimize U.S., Swiss and French taxes.
Assisted a U.S. franchisor of business systems to obtain, through the mutual assistance provision of the U.S.-Japanese income tax treaty, a refund of Japanese withholding taxes imposed on franchise payments.
Obtained a favorable private letter ruling from the IRS that reversed long-standing policy, allowing a spin-off of assets from a U.S. pension plan to a Puerto Rican plan with favorable tax consequences.
For many clients throughout the United States and internationally, designed solutions to implement business succession planning and individual estate planning goals.
On behalf of a global pharmaceutical company, secured a Pennsylvania state tax refund after convincing the Board of Finance & Revenue that a tax assessment against the company violated the U.S. Constitution.

INTERNATIONAL TAX