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By making a change of residence, a U.S. multinational corporation can take advantage of a more favorable tax structure.
Comparability is the key factor in determining the arm’s length range.
When valuing a business that is multinational in scope, develop a proper due diligence framework and apply models that will accurately reflect the company’s exposure to various risks.
When a company embarks on an international restructuring, it is extremely important to consider the impact of Section 367.
In the case of a U.S. acquisition of a foreign target, it was oftentimes beneficial to make a Section 338(g) election.