We advise U.S. companies on structuring issues related to:
- Forms of legal entities or branches that can be utilized outside the United States
- Use of holding company structures to minimize foreign withholding or disposition taxes
- Implications of transferring assets offshore
- Capitalization and/or debt financing of foreign operations
- "Check-the-box" planning
- Supply chain issues such as the use of limited risk distributor or commissionaire structures to create tax efficiencies
- IP migration strategies to move IP to lower tax jurisdictions through cost sharing and other strategies
- Foreign tax reduction strategies such as the introduction of leverage