Boston, MA Tax Lawyer: International
Whenever your employment or business takes you across a border you’re going to have a complex set of tax challenges to face.
This is an age when people, goods, and ideas travel in hours, sometimes moments, to almost any place on earth. In that is opportunity unbounded.
Both individuals and businesses pursue that bounty by moving themselves, their physical assets, and their intellectual property into or out of the United States. And every relocation has tax consequences that can make or break the undertaking.
All are subject to the plague of double taxation – paying tax on the same income both abroad and at home. And the tax code is replete with asset relocation penalties.
- Expatriated workers seeking opportunity and adventure in faraway places must be careful to claim every credit and income exclusion available to them
- Businesses moving assets abroad – especially intangible assets – without adequate planning can face dire and unexpected tax consequences, imposed by Code provisions designed to inhibit those very movements
- Foreign investors deploying capital inside the United States must know in advance whether they will be taxed on their worldwide income or only their U.S. income, and what their tax withholding responsibilities are
Tools exist to help businesses and individuals cope with the array of tax benefits, risks, and traps strewn across the field of international commerce.
- Direct and indirect foreign tax credits can reduce, even eliminate, the burden of double taxation
- Treaties between the United States and foreign jurisdictions contain many provisions helpful to international commerce
- Certain business structures can maximize your allowed foreign tax credit while others may reduce it
- Transfer pricing rules can help you understand when, and in what jurisdiction, your profits will arise
Tom is well versed in all these matters as a skilled international tax lawyer, and can help guide you through the process.
Read a paper Tom published in the journal Corporate Taxation (November/December 2012) on the indirect foreign tax credit and its application to cross-border business.
Read a paper Tom published in the journal Valuation Strategies (May/June 2013) on the perils of not planning for the international tax consequences of growth.
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Did You Know?
Dissolution of an LLC does not end its members' tax exposure.