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Estate & Gift Tax
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International Business Transactions
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Individuals
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Business Owners
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Professionals
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HNW Individuals and Families (U.S. and International)
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Family Offices
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Trust Companies
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Private Banks
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Insurance Companies
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Law Firms
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Accounting Firm
The International Group is unique within a boutique law firm setting and plays a pivotal role in our Firm. At Teeple Hall, LLP, we work with a deep understanding and appreciation for different cultures, customs and laws. The Firm strives to bring a practical, collaborative, and seamless level of service to individuals and businesses navigating the world of international transactions and planning.
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The professionals within the International Group bring a vast array of experience to the firm and approaches international planning cases with a deep breadth of knowledge, enthusiasm, and a zeal for assertive and ethical representation.
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Coupled with the Firm’s commitment and dedication to the resolution of complex issues with a depth of knowledge and experience, we deliver a wide array of sophisticated advice and counsel on international issues including:
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Advice on the formation and governance of foreign operating and holding company structures
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Choice-of-entity and jurisdictional analysis
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International corporate transactions
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International private client transactions (acquisitions involving property, aviation and art)
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International taxation, international transactions and acquisitions (individuals, families and trusts)
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International M&A transactions
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Formation and administration of foreign trusts (U.S. inbound and U.S. outbound)
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Asset protection planning
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U.S. inbound and U.S. outbound tax planning
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U.S. tax reporting and compliance work for international clients
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International
The International Group’s representative matters reflect the diversity of the Firm, its Practice Groups, and the wide range of international transactions and tax planning cases on which we advise.
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Advised a HNW individual who is a citizen of the U.K. on their U.S. contacts and residence options under both statutory and treaty-based tie-breaker provisions under the U.S. – U.K. Income Tax Treaty including the income tax and, more importantly, U.S. foreign reporting obligations under varying residence tie-breaker provisions. Our work included substantial coordination with Client’s advisor team in multiple jurisdictions.
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Advised a U.S. inbound family on pre-immigration tax planning for the ownership and contemplated sale of a privately owned business operated in their home country. The Firm managed the client’s immigration plans and coordinated and advised the home country’s legal and tax professionals, working to step-up the basis on the client’s operating company and avoid U.S. capital gains tax on a $20 million valuation of the company.
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Provided a formal tax opinion letter to a leading Swiss private bank on U.S. law regarding private placement life insurance products backing the bank’s legal and compliance team allowance of PPLI products within client accounts.
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Advised an Australian clothing manufacturer and distributor on U.S. income tax issues involving the warehousing of inventory and the U.S. and the tax treatment of online sales consummated abroad but with delivery in the U.S.
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Advised an UHNW family on pre-immigration tax and estate planning for a large portfolio of diverse assets including high-profile interests in several media projects. The project involved extensive coordination with the Client’s advisors in multiple jurisdictions.
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Advised a U.S. inbound individual on pre-immigration tax planning focused on both U.S. estate tax planning and, crucially, tax basis step-up planning and analysis on highly appreciated marketable and non-marketable securities, resulting in the recognition of substantial gain (in excess of $40 million) on the Client’s assets prior to obtaining U.S. Person status.
