Together with our international affiliates, Warady & Davis LLP assists clients with coordinating tax planning and compliance services both in the United States and abroad.
Our team provides international tax planning, consulting and compliance services in the following areas:
For Businesses & Corporate Entities
- Optimization of structures for foreign investment and business operations in the U.S.
- Structuring for acquisition, operation and disposition of U.S. real estate
- Controlled foreign corporation issues
- Interest Charge Domestic International Sales Corporations (IC-DISCs)*
* Through our affiliates
For Individuals & Trusts
- U.S. executives working and residing overseas
- Foreign executives working and residing in the U.S.
- Tax issues for non-citizens immigrating to the U.S.
- Tax issues for individuals considering expatriation from the U.S.
- Gift, trust and estate considerations for non-citizens with U.S. based assets
- U.S. beneficiaries of foreign trusts
Other Matters
- Income tax treaties and totalization agreements
- Foreign tax credits
- Subpart F and other anti-avoidance rules
- Tax aspects of foreign currency exchange
- Matters related to payments of U.S. source income to foreign persons
- IRS voluntary disclosures for U.S. persons with undisclosed foreign income and financial accounts
- Tax controversy, Competent Authority and other IRS matters