Cross-border decisions need integrated U.S. tax judgment
International tax issues can touch reporting obligations, residency, entity choice, treaty analysis, transfer pricing, FIRPTA, cross-border estate and trust structures, and controversy risk at the same time. Jason previously led the U.S. Tax Advisory Group at a Canadian tax firm, focused on inbound U.S. tax matters for high-net-worth individuals and entrepreneurs. The work is to make the U.S. position clear and defensible before it becomes contested.
Useful for
Individuals, families, entrepreneurs, and businesses with foreign income or assets, treaty questions, international business structures, inbound U.S. tax concerns, or international reporting analysis needs.
What this can include
- Advice concerning foreign-income and foreign-asset reporting obligations
- Treaty benefit analysis
- U.S. tax analysis of cross-border ownership and investment structures
- Inbound U.S. tax matters
- FIRPTA analysis
- U.S. tax analysis of cross-border estate and trust structures
- Transfer-pricing analysis in a broader legal engagement
- Representation in disputes involving international reporting or cross-border tax issues
Scope of cross-border work
The practice provides legal advice and representation concerning cross-border U.S. tax issues. It does not provide routine tax-return preparation or general estate-plan drafting.