International Taxation Gain control

Entering new markets also means entering new taxing jurisdictions, with the potential for double taxation of the same items of income. U.S. anti-tax deferral rules can also come into play, requiring the U.S. parent to pay current U.S. tax on the foreign subsidiary's income, even if not distributed. (As just one example, a pledge of a foreign subsidiary's assets to secure a parent-level borrowing can trigger current U.S. tax.) Through carefully considered structuring decisions, adverse tax surprises can be kept to a minimum. Through our TerraLex network, we can also draw upon the tax expertise of an international network of law firms in providing advice concerning non-U.S. tax matters to our U.S. clients. We also help many foreign companies manage their U.S., state and local tax obligations.