Practices

Outbound Activities of U.S. Clients

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... Read More

Inbound Activities of Non-U.S. Clients

Foreign based businesses that engage in U.S. transactions or business operations may be exposed to inefficient or possibly double taxation depending on the manner in which such activities are conducted.  Similarly, foreign nationals who intentionally or unwittingly acquire U.S. taxpayer status may be exposed to onerous U.S. income tax, gift or estate tax burdens... Read More

Tax Controversy and Litigation

The Internal Revenue Service has significantly increased its enforcement efforts in the international tax arena during the last decade, and Harrison Kemm has correspondingly represented a large number of individuals and businesses in disputes with the Internal Revenue Service... Read More