International Tax

Practice Area

Practice Areas
Team

The Firm’s work and services in the area of International Tax is unique for a boutique law firm and embodies our longstanding commitment to serving both U.S. and non-U.S. clients with international assets. 

The Tax Group works with a wide range of international tax issues and matters touching all aspects of our Practice Groups including (i) U.S. Income Tax Planning (Individual, Corporate, Trust), (ii) U.S. Estate Tax Planning (U.S., U.S. Inbound, U.S. Outbound), (iii) U.S. foreign compliance and reporting matters, (iv) voluntary disclosure of unreported foreign income, assets, entities, and (v) trusts and Audit & Tax Controversy.

The professionals within the International Tax Practice Group approach their work in this challenging practice area armed with a wealth of knowledge and experience in navigating a diverse range of international laws while collaborating with counterparts in other jurisdictions. 

As professionals who enjoy working with international clients and issues, we bring a profound sense of enthusiasm to our work which is exemplified in the Firm’s work product.
 

Experience & Expertise

Teeple Hall, LLP has significant experience and expertise in planning and executing strategies involving:

  • International Income Tax Planning (U.S. Inbound)

    • Planning for U.S. inbound investment

    • Planning for U.S. inbound wealth transfers

    • Pre-immigration income and estate tax planning

    • FIRPTA analysis and planning

    • U.S. Income Tax Treaty analysis and planning including advice on availability and limitations on benefits under available treaties

    • Analysis and advice on treaty- and statutory-based closer-connection positions for tax residence purposes

    • Analysis and advice on treaty- and statutory-based closer-connection positions for U.S. foreign reporting and tax compliance matters

    • Corporate and business transactions

    • M&A advisory and consulting

    • Tax planning for foreign operations of U.S. based companies

    • Tax planning for U.S. operations and activities of foreign individuals and companies

  • International Income Tax Planning (U.S. Outbound)

    • U.S. income and estate tax planning reporting for U.S. individuals, companies and trusts with foreign assets, entities and trusts

    • Planning for foreign-source income and coordination with local counsel on local country tax issues

    • U.S. Income Tax Treaty analysis and planning including advice on availability and limitations on benefits under available Treaties

    • Corporate and business transactions

    • M&A advisory and consulting

    • Coordination with local jurisdiction tax and legal advisors on jurisdiction tax issues and tax planning

  • Private Client Taxation

  • U.S. Foreign Compliance and Reporting

  • Voluntary Disclosure

  • Expatriation Planning including

    • Planning for expatriation on relinquishment of U.S. citizenship including planning and strategy to avoid/minimize “covered expatriate” status under IRC 877A

    • Planning for relinquishment of U.S. permanent resident status including planning and strategy to avoid/minimize “covered expatriate” status under IRC 877A

    • Advice and counsel on implications of involuntary loss of a Green Card

  • Audit & tax controversy including U.S. Tax Court litigation

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