International Tax Planning

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McLane Middleton is accomplished in helping U.S. and non-U.S. clients conduct their international business operations.

Our attorneys regularly advise companies on the following complex international tax issues:

  • Choosing the correct business entity and restructuring foreign operations to minimize U.S. and foreign taxation
  • Planning for and determining the correct source of business and non-business income
  • Minimizing taxation through proper employee compensation structures
  • Working with foreign tax systems
  • Understanding the impact of U.S. tax treaties
  • Maximizing allowable foreign tax credits
  • Intercompany (transfer) pricing matters
  • Foreign currency affairs
  • U.S. controlled foreign corporations (CFC) and passive foreign investment company (PFIC) regimes.

Our history of success includes the structuring of a sale between a U.S. business with foreign subsidiaries in Germany and the Netherlands. This case handles repatriation of foreign source income, foreign tax credit allocation, the applicability of various tax treaties, Netherlands real estate transfer taxes, withholding rules for corporate dividends, and several pension concerns.

McLane Middleton is a member of Terralex, a worldwide network of independent law firms helping domestic and foreign clients to do business globally. Our attorneys are frequently asked to provide tax guidance to clients of other member firms.


For additional information, contact John Rich, chair of the firm's Tax Department.