A number of specialized federal tax rules apply to U.S. businesses or individuals that directly or indirectly conduct business or investment activities abroad. Careful planning is required to minimize the effective global tax cost of such “outbound” activities, and to comply with complex U.S. reporting requirements.
Harrison Kemm P.A. provides legal advice for a wide variety of transactional and tax planning outbound investment matters. Such matters routinely implicate the specialized U.S. tax rules governing controlled foreign corporations, passive foreign investment companies, foreign tax credits, foreign currency, and tax treaties, among others.
Planning with respect to outbound investment frequently includes structuring arrangements to minimize or defer U.S. taxation of profits, to avoid foreign taxation, to maximize foreign tax credit utilization, to deduct foreign losses, or to otherwise benefit from the arbitrage between U.S. and foreign tax rules. Harrison Kemm routinely advises on such planning in the context of structuring start-up operations, structuring foreign mergers, acquisitions and dispositions, or restructuring existing foreign operations. Such planning often involves aspects of operations that include offshore manufacturing, international financing, intangible property licensing and royalties, as well as distribution arrangements or service relationships.
As necessitated by any particular project, Harrison Kemm will liaise with foreign tax counsel to provide advice and counsel on non-U.S. tax matters. Through years of experience, Harrison Kemm maintains an extensive network of contacts of foreign tax advisors that enables the firm to select the best lawyer in a particular location for the type of work required.