International Tax Planning
Troutman Sanders' clients have an expanding international scope of business. To meet their needs, the Tax Group includes attorneys who are well-versed in international taxation. They also assist foreign clients with investments in U.S. businesses and real estate. The Firm's international tax attorneys develop and implement transaction structures designed to achieve worldwide tax efficiencies, and provide planning advice to minimize the adverse foreign tax consequences on repatriating earnings. In addition, they have structured numerous acquisitions of U.S. corporations and U.S. real estate investments on behalf of foreign persons. The Group has experience with transfer pricing planning and defense. Examples of their international experience include:
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Advising U.S. companies operating businesses and making investments in infrastructure development transactions overseas.
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Advising clients with regard to withholding tax planning and structuring royalty arrangements.
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Advising lessors, lessees and financiers in cross-border leasing transactions and international aircraft leases.
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Transfer pricing planning under Internal Revenue Code Section 482, minimization of foreign tax and U.S. earnings and profits, foreign tax credit utilization and treaty protection.
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Analyzing tax effective financing transactions.
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Advising several major Japanese and European companies on investments in real estate and operating businesses in the U.S.
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Advising clients of tax implications of transactions in connection with privatization efforts in numerous countries, including Portugal, Hungary, Ireland, Australia, Poland, Jamaica, The Bahamas, Hong Kong, Germany and the United Kingdom.
The Group believes in a global approach to tax planning by creating structures which satisfy business needs while lowering worldwide taxes. They work with overseas advisors to understand the tax systems of the countries in which clients operate, and carefully consider increased or decreased offshore tax with the countervailing effect on U.S. taxes. As a result of this international work, they have developed strong working relationships with local law, accounting and consulting firms in a number of countries. This greatly enhances the Group's ability to ensure that all applicable tax laws are addressed. In addition, the Group's attorneys have developed extensive knowledge of the tax laws of certain foreign countries, including those that have, in effect, a treaty with the United States and those that do not.