San Francisco Tax Attorney: International Tax Representation
Our firm's rapidly growing International Tax Practice covers a range of international business activities and taxes. We provide ongoing advice to U.S.-based businesses concerning all U.S. federal and state income tax rules relevant to foreign operations, as well as general advice concerning non-U.S. taxation. We advise from the inception of business operations in a foreign country to the disposition of a business.
GoldPoint Law Group has a sophisticated diversity of clients and our attorneys remain on the cutting edge of new tax planning ideas around the world. In addition, we are on the forefront of current law changes and global opportunities through frequent communication with our affiliates in foreign jurisdictions.
Reduction of Worldwide Tax Rate
We advise clients on ways to reduce their worldwide effective tax rates to the furthest extent possible under applicable laws. Some of our techniques include leveraging foreign subsidiaries to reduce foreign taxes, revamping inter-company pricing and royalty payments, contracting manufacturing and other principal structures, cross-border leasing transactions and increasing low-taxed foreign source income to utilize excess foreign tax credits. In this regard, we work with clients to develop capital structures and repatriation strategies for minimizing worldwide taxation.
Formation / On- Going Operations
In this global economy, all companies -- from start-ups to well-established businesses seeking to expand their operations -- benefit from having a foreign presence. We work extensively with our clients on the important task of building that foreign presence. Our work includes formation of foreign distribution and purchase arrangements that avoid foreign taxation. In addition, we structure operations maximizing opportunities for deferral of U.S. tax on foreign earnings.
We counsel our clients about the special federal income tax rules that apply to U.S. businesses operating abroad, including:
- The “subpart F” controlled foreign corporation regime
- Tax Treaties
- Transfer pricing
- Foreign tax credits
- Passive foreign investment company rules
- Outbound stock and assets transfers
- Foreign currency
- Limiting deductions for foreign losses
Foreign Acquisitions and Dispositions
We structure and negotiate acquisitions and dispositions of foreign companies, planning for the most tax efficient structures from both non-U.S. and U.S. businesses. Some of the issues include asset versus stock purchases, foreign or United States ownership, and the form of business entity. Acquisition planning ideas include elections to treat certain stock purchases as asset purchases, maximize cash flow flexibility and leveraged holding companies to reduce foreign taxes.
Restructuring Foreign Operations
As a result of changes in business climates, we advise clients concerning restructuring existing foreign operations with a focus on tax planning. This advice may involve downsizing a business, changing the country of operation or converting to a pass-through entity in order to obtain tax benefits for foreign losses. To meet our client’s objectives, we obtain tax rulings and work with other counsel to obtain all necessary rulings and clearances where we do not have our own office.
We have extensive experience handling inter-company pricing issues in the United States and throughout the world. We advise our clients on transfers of intangibles to foreign affiliates, services and inter-company transfer pricing matters. We have been involved in the preparation of detailed pricing reports, which require economic analyses and industry experts, as well as the development of strategies to best present our client’s position and the case to the taxing authority. To advance our client’s interests, we work with senior economists and pricing specialists at major accounting and economic consulting firms.