International Tax Attorney

individuals investing abroad must be aware not only of the complex and often punitive U.S.
tax regimes that may apply to such investments, such as the subpart F, GILTI, and PFIC
regimes but also of the U.S. reporting requirements associated with such investments.
Investing through common estate planning structures, such as trusts, can add an additional
layer of complexity. International tax attorneys New York have extensive experience
advising clients on such investments, and our International Tax group works closely with the
attorneys in the Private Client Group to mitigate tax exposure and avoid compliance
mistakes that can result in costly penalties.
The intricate rules governing foreign tax credits are of fundamental importance for U.S.
taxpayers with cross-border operations and income. International attorneys have extensive
experience and expertise in navigating these ever-changing rules, including not only basic
questions of creditability under U.S. tax law and tax treaties, but also the equally important
provisions relating to the foreign tax credit limitation, the deemed paid credit, the
requirements for substantiation, and the special currency, accounting, and carryover rules
pertaining to the credit.

International Tax Attorney New York is the best choice

The following areas come under international attorney:
 Formation of business entities and joint ventures
 Corporate governance, resolutions, consents, directors and shareholders meetings,
and minutes
 LLC operating agreements and shareholder's agreements, including buy/sell
agreements
 Purchase and sale of businesses
 Employment issues, including hiring, retention, termination and employee
agreements and handbooks
 Executive compensation agreements
 Commercial contracts, licensing agreements and strategic transactions, including
independent contractor agreements, non-compete and non-solicitation agreements,
invention agreements, and NDA and confidentiality agreements
 Federal and state trademark registrations and other intellectual property protection
 Advise officers and directors on fiduciary duties and strategic considerations
 Conduct legal audits to review the company’s practices for the potential of piercing
the corporate veil and other exposure to liabilities
Foreign government investors, including sovereign wealth funds, and foreign public and
private pension funds, are among the many investors who seek yield in the U.S. private
equity and real estate markets
Structuring into and maintaining qualifications for the tax exemptions for foreign sovereigns
and pension funds require careful planning and ongoing vigilance

We offer a unique outside general counsel program for small and large clients who want
outside counsel to handle corporate formalities and legal issues, without incurring the high
overhead associated with in-house counsel. We provide businesses with the ability to have
experienced legal counsel at their disposal on an “as-needed” basis. In our role as outside
general counsel, we work closely with clients to gain an in-depth understanding of their
business activities and objectives. Because of this, we are able to provide focused, client-
centred, and cost-effective advice and counsel to our client’s business-related legal issues