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International Taxation

Foster Swift's tax group is comprised of attorneys experienced in the intricacies of international taxation, including the taxation of exports and imports, transactions between domestic and international companies and affiliates, the tax consequences to a foreign company of doing business in the United States as well as the taxation of inbound and outbound employment arrangements. We work closely with clients to understand their businesses and provide practical and cost effective solutions to their international tax issues.

To help reduce expenses and obtain the best representation possible for our clients, we regularly work with clients' accounting departments, CPAs and consultants. We also leverage the Firm's capability in other areas, including corporate and finance, real estate and estate planning

Areas of expertise include:

  • Advising foreign clients with respect to their U.S. investments
  • Counseling clients in cross-border transactions and multijurisdictional corporate activities
  • Assisting clients with transfer pricing issues
  • Helping clients navigate the Foreign Account Tax Compliance Act (FATCA) and other rules and regulations, including the Controlled Foreign Corporation (CFC) rules and the Passive Foreign Investment Company (PFIC) rules
  • Advising businesses expanding operations globally, including expansions in Asia and South America

  • Advising domestic clients regarding the tax consequences of employment and benefits arrangements for inbound and outbound executives

  • Structuring private equity investments into the U.S.

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