Solutions for Global Clients

Non-U.S. individuals and businesses investing in or relocating to the United States face a complex web of U.S. tax rules that, if not properly navigated, can result in unexpected tax costs, withholding, and penalties. We advise foreign nationals, non-resident aliens, and internationally mobile individuals on structuring their U.S. activities and investments in a tax-efficient manner. Learn more.

U.S. citizens and residents are taxed on their worldwide income, regardless of where they live. American individuals living abroad — whether in Spain, France, Latin America, or elsewhere — face significant U.S. tax reporting obligations and planning opportunities, including PFIC exposure from foreign investment vehicles, Net Investment Income Tax, and dual-filing compliance. We help U.S. persons structure their global affairs in a tax-efficient and fully compliant manner. Learn more.

Renouncing U.S. citizenship or relinquishing a green card after long-term residency triggers one of the most complex and consequential tax events in U.S. tax law — the exit tax under Section 877A. Without careful planning, expatriation can result in a deemed sale of all worldwide assets and significant tax liability. We guide clients through every stage of the expatriation process, from initial analysis through final compliance. Learn more.

U.S. persons with foreign financial accounts, interests in foreign entities, or ownership of foreign trusts face an extensive array of annual reporting and disclosure obligations. The penalties for non-compliance can be severe — in some cases exceeding the value of the underlying asset. We help individuals and businesses understand their obligations and achieve and maintain full compliance. Learn more.

U.S. real estate is one of the most popular investment classes for internationally mobile and foreign individuals — but it carries significant U.S. tax complexity. FIRPTA withholding, U.S. estate and gift tax exposure for non-resident aliens, income tax on rental income, and classification of LLC interests as U.S.-situs assets all require careful planning. We structure U.S. real estate holdings to minimize tax friction while achieving the client’s investment and succession goals. Learn more.

When a family member passes away and assets, heirs, or both span multiple countries, the U.S. tax implications can be significant — and easy to miss without specialized counsel. Cross-border inheritance matters sit at the intersection of U.S. estate tax, income tax, and international information reporting. For non-resident aliens who hold U.S.-situs assets at death, even modest holdings can trigger U.S. estate tax liability, banking freezes, probate proceedings, and IRS transfer certificate requirements — a system that is difficult to navigate without planning. Learn more.

High-net-worth individuals and families with connections to multiple countries face unique challenges in structuring their wealth for both tax efficiency and generational transfer. Foreign trusts, offshore entities, civil law structures such as usufructs, and internationally mobile beneficiaries all create layers of U.S. tax complexity. The distinction between foreign grantor and foreign nongrantor trusts — which determines who is taxed on trust income, how distributions are treated, and whether the throwback rules apply — is central to any cross-border planning engagement. Learn more.

International entertainers and athletes face some of the most complex tax situations of any individual taxpayer. Touring income earned across multiple countries, image rights and licensing arrangements, endorsement deals, foreign withholding taxes, and treaty-based exemptions — all layered on top of the standard U.S. international tax framework — require advisors who understand both the technical rules and the practical realities of a performance-based, globally mobile career. Learn more.

Entrepreneurs and families who own closely held businesses — whether expanding a U.S. business abroad or bringing a foreign business into the United States — face a distinct set of international tax challenges. Relocating a U.S. business owner to a foreign jurisdiction introduces permanent establishment risk, dual-filing obligations, and entity classification issues that must be addressed from the outset. The wrong structure can trigger unexpected U.S. tax costs, double taxation, or reporting penalties; a strategy that works aligns the business structure with the individual’s residency from the beginning. Learn more.

Transactions

International tax advisory for buyers, sellers, and deal teams in cross-border mergers, acquisitions, and investments — identifying exposure, informing structure, and protecting value.

From FIRPTA analysis to CFC exposure, transfer pricing risk, and post-closing integration.

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Representing parties in complex cross-border commercial disputes under ICC, ICDR/AAA, UNCITRAL, and ad hoc rules across multiple jurisdictions and legal systems. Learn more.

Advising and representing investors and states in treaty-based disputes under ICSID, UNCITRAL, and other frameworks involving bilateral and multilateral investment treaties. Learn more.

We represent businesses and organizations throughout every stage of the arbitration process, from drafting arbitration agreements to obtaining and enforcing final awards. We handle high-value commercial disputes involving multinational parties across a wide range of industries. Learn more.

We assist businesses involved in cross-border litigation arising from international contracts, commercial relationships, and multinational transactions. Our team provides strategic guidance through complex jurisdictional, procedural, and substantive issues in U.S. federal courts. Learn more.

We represent clients in proceedings involving the confirmation, enforcement, modification, or challenge of international arbitral awards under applicable international conventions and U.S. law, helping ensure awards are effectively recognized across jurisdictions. Learn more.

We help clients navigate disputes that involve both arbitration and litigation, developing coordinated strategies to protect their interests while managing procedural risks across domestic and international forums. Learn more.