International Tax

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.

Crowell’s international tax team advises 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).