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OVERVIEW

International Taxation Gain control

Our clients' international activities have been robust in recent years with the creation and expansion of foreign sales and manufacturing operations.

Entering new markets also means entering new taxing jurisdictions, with the potential for double taxation of the same items of income. U.S. anti-tax deferral rules can also come into play, requiring the U.S. parent to pay current U.S. tax on the foreign subsidiary's income, even if not distributed. (As just one example, a pledge of a foreign subsidiary's assets to secure a parent-level borrowing can trigger current U.S. tax.) Through carefully considered structuring decisions, adverse tax surprises can be kept to a minimum. Through our TerraLex network, we can also draw upon the tax expertise of an international network of law firms in providing advice concerning non-U.S. tax matters to our U.S. clients. We also help many foreign companies manage their U.S., state and local tax obligations.

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