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International Tax

Miles & Stockbridge has a substantial practice involving the dual aspects of international business taxation: advising companies headquartered in other countries on tax strategies for their US operations and advising domestically based companies on tax strategies for their international subsidiaries and partnerships. 

We advise clients on the effects of international treaty provisions that control much of the planning for international operations and recommend effective alternatives to minimize the tax burden of cross-border operations.  Our lawyers have sophisticated knowledge and experience to analyze and recommend optimal strategies for each corporate structure and operation and their effect on taxation. 

In addition to the tax aspects of ongoing operations, we advise domestic and foreign companies on the tax implications of transactional matters, including mergers and acquisitions and related finance considerations.  Where international business combinations involve the exchange of stock registered in another country; we design the deal structures that make such exchanges possible and advise shareholders on the tax treatment of the stock they receive.  In non-stock organizations, such as establishing joint ventures with foreign partners, we ensure that the deal is structured to minimize the tax consequences for all parties.  In situations involving loans and letters of credit, we handle the tax issues that the borrower faces in its cross-border payments.

Finally, our tax lawyers use their broad knowledge of the tax laws to advise domestic and foreign companies on a host of day-to-day issues, including:

  • US tax treatment of foreign nationals working in this country
  • Tax laws of other countries as they apply to Americans working overseas
  • Tax planning for the transfer of executives across borders
  • Tax planning for import/export operations, including the law as it applies to warehousing and shipping facilities
  • The tax implications of finance subsidiaries, self-insurance subsidiaries and other offshore corporations
  • International estate tax planning and administration