PRACTICE AREA
Cross-Border Business Structuring for Closely Held Companies
U.S. Tax Planning for Entrepreneurs and Family Businesses Operating Across Borders
Entrepreneurs and families who own closely held businesses — whether expanding a U.S. business abroad or bringing a foreign business into the United States — face a distinct set of international tax challenges. Relocating a U.S. business owner to a foreign jurisdiction introduces permanent establishment risk, dual-filing obligations, and entity classification issues that must be addressed from the outset. The wrong structure can trigger unexpected U.S. tax costs, double taxation, or reporting penalties; a strategy that works aligns the business structure with the individual’s residency from the beginning.
Our Services Include:
Outbound structuring — advising U.S. business owners on the tax-efficient expansion of operations abroad
Inbound structuring — advising foreign entrepreneurs on establishing U.S. operations in a tax-efficient manner
Permanent establishment risk analysis for U.S. businesses managed from abroad
Entity classification planning — check-the-box elections and the tax consequences of different entity forms
Controlled Foreign Corporation (CFC) analysis and planning — Subpart F income, GILTI, and FDII
Holding company structuring for internationally owned businesses
Tax-efficient repatriation of foreign profits to U.S. owners
Exit and succession planning for owners of cross-border businesses
Coordination with foreign counsel for multi-jurisdictional structuring engagements