International Tax

We provide international tax planning and represent individual and corporate clients before the Internal Revenue Service (IRS) and the United States Tax Court. U.S. citizens and permanent residents who invest, work or live in foreign countries are taxed on their worldwide income. Foreign nationals who invest or work in the U.S. may be taxed on their income derived from the U.S.; however, if they are have been present in the U.S. for 183 days or more they may be considered to be permanent residents for tax purposes and will be subject to U.S. taxes on their worldwide income. The 183-day test also applies if the total number of days the person was present in the U.S. in the current year, plus 1/3 of the number of days the individual was present in the preceding calendar year, plus 1/6 of the number of days the individual was present in the second preceding year equals or exceeds 183 days.

The U.S. international tax laws are complex and ever changing. Corporations and individuals involved in international transactions in the U.S. and abroad can effectively reduce, avoid or defer their U.S. taxes through efficient tax planning.

The following are common international tax issues faced by taxpayers:

  • Taxation of foreign nationals working in the U.S.
  • Foreign tax credit issues
  • Transfer pricing issues affecting an entity and its related parties
  • Taxation of shareholders who own controlled foreign corporations
  • Transfer to or from a foreign trust
  • Taxation of professionals working in multiple countries, including athletes, musicians, entertainers and artists
  • Tax treaties


DISCLAIMER: The information given in this website is intended as general information only and is not a substitute for the services of a tax attorney in your specific case.