Our clients cover a broad spectrum, from Fortune 500 companies and multinational corporations to tax-exempt organizations and closely held businesses. We counsel them on corporate transactions and financings; tax controversy, advocacy and litigation; legislative and regulatory activities; executive compensation and tax planning; international, federal, state and local taxation; and foundation and exempt organization matters.
Non-U.S. entities rely on us for advice on tax planning opportunities and compliance requirements related to acquiring or investing in U.S. real property, including compliance with the Foreign Investment in Real Property Tax Act. We assist foreign investors in developing tax-efficient strategies for structuring start-up business ventures in the United States. We counsel U.S. entities on controlled foreign corporation, Subpart F and passive foreign investment company matters and advise U.S. companies with insolvent foreign subsidiaries on tax planning opportunities. In addition, we provide guidance to U.S. and foreign entities on withholding tax, permanent establishment, limitations on benefits and other tax treaty issues.