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International Taxation
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Rachlin's International Taxation Group provides
U.S. income tax planning and compliance services to
foreign companies doing business and investing in
the United States and to U.S. companies expanding
operations abroad. The Group also advises U.S.
executives on the planning opportunities and tax
aspects of working abroad and advises foreigners
working or looking to migrate in the U.S.
A significant part of our practice is focused on
foreign investments in U.S. real estate. We represent
a wide array of clients ranging from first time
individual investors to multi-national corporations
with investments into the hundreds of millions of
dollars. We help foreign clients identify the entity
structure that fits the tax profile of the business and its owners. During the
ownership phase, we provide tax planning and tax
preparation services. At the time of sale, we focus
on minimizing the tax impact of the sale and
enhancing the after tax cash flow to the business
owners.
Another significant part of our practice is advising
U.S. companies and citizens that have ownership
interests in foreign corporations and foreign partnerships.
We assist clients in structuring their business
operations and identifying planning opportunities and
tax treaty benefits. For clients who sell goods and
services abroad, we help them benefit from special
tax incentives available to U.S. exporters.
Our group works with foreign executives and
high-tech professionals on assignment in the U.S.
We provide pre-assignment tax planning and map out
the U.S. federal and state tax implications and planning
opportunities, including treaty analysis. For U.S. executives
working abroad we focus on how the executive
can reduce their U.S. tax exposure based on special
wage and housing exemptions and foreign tax credits.
We also work regularly with foreigners and their
families who migrate to the U.S. out of political and
safety concerns. We advise on the tax implications of
having business interests and other holdings outside
the U.S. and how to reduce their U.S. tax exposure. We also address pre-immigration tax planning to
reduce the impact of the U.S. income and estate tax.
Rachlin's International Taxation
services include:
- General compliance services to ensure that
U.S. corporations and individuals with business
or investments overseas, comply with all IRS
reporting requirements.
- Guidance for domestic corporations doing business
abroad, including setting up sales offices and
manufacturing operations and recommending the
most advantageous investment structure
- Tax services for U.S. individuals working abroad,
including planning to minimize tax exposure and
ensuring that individuals receive appropriate
tax breaks
- Guidance to ensure that domestic corporations
who export U.S. made goods, or are considering
the export of U.S. made goods, understand and
take advantage of the benefits and incentives
available to them
- Income tax services for U.S. individuals with
beneficial interests in foreign trusts to ensure that
all tax implications and compliance requirements
are understood and addressed
- Accounting and tax services for foreign nationals
and businesses controlled by foreign persons,
including income tax assistance for the corporation
and its key executives as well as financial
statement preparation
- Tax planning and compliance services for U.S.
real estate investments including strategies for
sale of U.S. real estate minimize exposure and
ensure compliance with all applicable laws
- Guidance for international corporations looking
to do business in the U.S., including investment
structure, tax assistance, general compliance
and financial and tax services for key executives
- Estate tax planning to address and minimize
the significant tax implications for foreign nationals
who die while owning a vacation home or other
real estate in the U.S.
- Pre-immigration tax planning for wealthy
individuals and families moving to the U.S. to
reduce exposure to U.S. taxes and adherence
with all compliance requirements
- Strategies to reduce U.S. withholding tax
- Estate tax returns for nonresident aliens
- Representation of non-filers who have
resided outside the U.S. for extended periods
- Tax controversy and other IRS matters
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