International Taxation

WTAS has extensive experience in advising multinational businesses on tax aspects of international activities, including new and traditional tax planning opportunities. Significant international tax practice areas include:

• Structuring/restructuring non-U.S. operations of U.S.-based corporations for more efficient management of their global tax position, including matters such as entity selection, use of holding companies, tax treaty issues, financing issues, foreign tax credit planning, migration of intangible property through cost-sharing and coordination with local-country advisors
• Structuring inbound U.S. investment of non-U.S. corporations, including overall structure, financing issues and U.S. tax on income from operations
• Developing, implementing and supporting intercompany pricing structures
• Foreign tax credit maximization, including determining eligible credits, income-sourcing rules, credit redeterminations and basket-transitioning rules
• Subpart F income to maintain tax deferral on income from non-U.S. operations
• Alternative investment vehicles including structuring hedge, private equity and venture capital funds to minimize U.S. taxation of U.S. and non-U.S. investors
• Effective use of passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs)
• U.S. taxation of foreign-currency gains/losses