berkowitz pollack brant advisors and accountants

International Tax Planning and Compliance

Our firm’s international tax practitioners are widely recognized as thoughtful advisors, strategic thinkers and valuable business partners. Many of our multi-national clients have worked with us for many years as their companies have grown and evolved.

Tax Planning and Compliance

  • Subpart F income calculations
  • Branch terminations
  • International debt equity strategies
  • FIRPTA withholding tax certificates
  • Federal, state and local tax compliance for US businesses with foreign owners
  • Assessing the tax impact of currency fluctuations
  • Foreign corporations’ ownership of US companies and partnerships

International Tax Consulting

  • Foreign tax credits
  • Branch profits
  • Using treaties to mitigate tax costs of cross-border transactions
  • Expatriate tax services for employees
  • Assisting relocation to US under EB-5, L2, L-1 and other visa programs
  • Residency elections and dual-residence filing
  • Compensation planning
  • Foreign gifts and inheritance
  • CFC Consulting
  • Branch profits tax calculations
  • FIRPTA planning
  • Preparation of treaty-based disclosures
  • Foreign earned income exclusion
  • Transactions with foreign related parties
  • Joint ventures with foreign partners

International Tax Consulting

  • Change-in-accounting method to US dollars as the functional currency
  • Transfer pricing benchmarking studies
  • Transfer pricing documentation studies
  • IC-DISC and export tax incentives
  • Strategic planning, including issues such as choice of country or legal entity
  • Intellectual property holdings
  • Tax planning for foreign trusts and estates
  • Corporate structures
  • Financing foreign operations
  • Exchange controls and repatriation of capital and profits
  • EB-5 project structuring
  • Pre-immigration planning
  • Wealth preservation projects
  • Preparation of estate plan including tax planning for international investors

International Transactions

  • Due diligence for outbound and inbound transactions
  • 338(g) elections for acquisitions of foreign corporations
  • Exchange controls and repatriation projects

IRS Representation

Our tax professionals have significant experience representing clients in cross-border Internal Revenue Service (IRS) administrative proceedings. As the IRS expands its reach and the tax code becomes more complex, individuals and companies can inadvertently step into gray areas. International entities face even more complicated situations. Our team provides insight, guidance and representation.


  • Representation of foreign corporations and non-resident aliens in IRS examinations
  • Correspondence relative to FIRPTA withholding certificates
  • Applying for section 1446 relief – Certificates of Reduced Partnership Withholding
  • Preparation of applications for US tax clearance (residency certificates)
  • Negotiation of central withholding tax agreements
  • Application for tax identification number for non-resident aliens
  • Application for employer ID for foreign corporations
  • Calculation of US withholding tax for payment by foreign persons
  • Representation of US-based multi-national companies in IRS examinations


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