Erwin Law Firm

Bespoke International Tax Planning

AREAS of PRACTICE

The firm advises on U.S. Taxation of International Transactions. This includes the following areas:

  • Inbound: Investments into the United States by non-U.S. individuals and companies and the U.S. tax consequences of non-U.S. persons operating businesses and owning property in the United States. This includes tax aspects of immigration and, often, state tax, company governance, and contract matters. The firm has particular experience advising artistes and entertainers.
  • Outbound: Investments by U.S. persons outside the United States. The firm has particular experience advising on investment into and activities in Europe and the Caribbean. Advice in this category often includes tax treaty analyses, transfer pricing studies, and explaining the tax consequences of transfers of intellectual property. The firm also advises individuals on expatriation. The firm has extensive experience regarding investment incentives in the territories of the United States.
  • Cross-Border Estate Planning: Advising on the tax consequences of foreign gifts, foreign trusts, Privatstiftungen (private foundations) and foreign estates of U.S. individuals and foreign individuals with U.S. connections and family. This includes advising specially designated nationals and advising on pre-immigration arrangements, asset protection structures, and post-mortem planning.
  • Federal Tax Controversies: The firm represents individuals and companies in tax audits and tax litigation in U.S. federal courts. The firm also advises on voluntary disclosures.
  • Certifying Acceptance Agent: The firm assists in obtaining Individual Taxpayer Identification Numbers (ITINs) under the expedited Acceptance Agent Program authorized by the Internal Revenue Service.