International Tax

U.S. executives working and residing overseas

Foreign executives working and residing in the U.S.

Tax issues for non-citizens immigrating to the U.S.

Tax issues for individuals considering expatriation from the U.S.

Gift, trust and estate considerations for non-citizens with U.S. based assets

U.S. beneficiaries of foreign trusts

Foreign withholding tax matters

Application of income tax treaties to amounts subject to withholding at source

Application of U.S. withholding rules to offshore withholding agents

Backup withholding matters

Income tax treaties

Foreign tax credits

Subpart F and other anti-avoidance rules