Whether in an international or subnational context, cross-border transactions necessarily implicate the competing interests of multiple jurisdictions to impose and collect income, franchise, transfer, excise, sales and use, property and value added (VAT) taxes. Fortson, Bentley and Griffin’s tax and corporate attorneys have the knowledge and experience to assist manufacturers, distributors, franchisors, service providers, financial institutions, private investors, and other clients structure their business affairs to avoid double taxation and minimize the administrative and reporting burdens associated with cross-border transactions. Particular areas of expertise include
- U.S. Taxation of International Transactions: including residency and income source rules
- Inbound Transactions by Foreign Persons: including business entity and investment vehicle selection, taxation of effectively connected business income and investment “FDAP” income, withholding taxes, branch profits tax, structuring of investments in U.S. commercial real property and U.S. timberland, Foreign Investment in Real Property Tax Act (FIRPTA), treaty benefits and withholding exemptions, earnings stripping rules, and permanent establishments
- Outbound Transactions by U.S. Persons: Including foreign tax credit planning, transfer pricing issues, controlled foreign corporations (CFCs), Subpart F income and passive foreign investment companies (PFICs), and foreign bank account reporting (FBARs)
- Multi-state Transactions: including jurisdictional nexus issues, intangible holding companies, Public Law 86-272, income and deduction allocations, formulary apportionment, and tax credits
If you are seeking experienced legal representation for a multi-jurisdictional tax issue, please contact us online or by telephone at 706-548-1151 to speak with one of our experienced tax attorneys.