Background - Practices (Details)

International Tax

Contacts

At Crowell & Moring, we have extensive experience representing taxpayers on a wide array of international tax issues. Our Chambers and International Tax Review recognized lawyers regularly advise multinational corporations and joint ventures regarding the U.S. tax aspects of their most important inbound and outbound transactions, including developing and documenting tax-efficient transfer pricing policies.

We advise U.S.-based taxpayers on the tax laws applicable to outbound investments, including outbound stock and asset transfers, transfers of intangibles, transfer pricing, cost sharing, foreign tax credits, subpart F, passive foreign investment company rules, the base erosion and anti-abuse tax (BEAT), and global intangible low-taxed income (GILTI). We also advise on the tax aspects of restructuring international operations.

We advise foreign-based taxpayers on the tax aspects of operations and investments in the United States, including inbound mergers and acquisitions, operating through a U.S. trade or business, permanent establishments under the U.S. treaty network, branch profits taxes, withholding taxes, and specialized U.S. tax regimes such as the Foreign Investment in Real Property Tax Act (FIRPTA).

Our lawyers have settled numerous international tax issues before the IRS Examination Division and the IRS Appeals Office; and, where settlement was not possible, our lawyers have represented taxpayers with significant international tax issues in court.

We have represented taxpayers in hundreds of advance pricing agreement (APA) and competent authority matters before the IRS’s Advance Pricing & Mutual Agreement (APMA) Program on transfer pricing and permanent establishment issues and the IRS’s Treaty Assistance and Interpretation Team (TAIT) on other treaty issues. These matters have involved issues between the United States and numerous countries, including, for example, Canada, Japan, Switzerland, India, China, the Netherlands, Mexico, Australia, Israel, and Germany.

Our lawyers are demonstrated thought leaders in the area of transfer pricing. For example, one of our lawyers is the editor of the Transfer Pricing Answer Book, published by the Practising Law Institute since 2012 and another was an original co-author of A Practical Guide to U.S. Transfer Pricing, published by Aspen Publishers.