International Tax

Overview

At Crowell we have experience representing taxpayers on a wide array of international tax issues. Our lawyers 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.

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).

Insights

Event

Federal Bar Association—2022 Tax Law Conference

Join the Section on Taxation for the 46th Annual Tax Law Conference on March 3-4, 2022. This newly formatted two-day program will offer the same great content in-person and online. Programming will be held exclusively in-person on Thursday, March 3 and exclusively virtually on Friday, March 4....

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