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International Tax

Overview

Parker Poe attorneys have extensive international tax planning experience. Our tax attorneys regularly serve as U.S. tax counsel to multinational corporations, advising them on the tax implications of conducting business and investing in the U.S.

We assist clients with choice of entity and site selection decisions and in obtaining tax incentives from state and local governments. We also assist U.S. residents with outbound tax planning, including the implementation of strategic tax-deferral strategies. We regularly represent clients in cross-border M&A transactions and in the restructuring of multinational corporations.

In addition to our tax planning and transactional work, Parker Poe represents foreign corporations and nonresident individuals in disputes before the Internal Revenue Service and state taxing authorities. Our international tax compliance team frequently assists clients with informational reporting and withholding issues and helps clients come into compliance with U.S. tax law through voluntary disclosures to the IRS.

Representative Experience

  • Advised multinational conglomerates on complex tax matters related to:
    • Subpart F.
    • Foreign Account Tax Compliance Act (FATCA).
    • Global Intangible Low-Taxed Income (GILTI).
    • Dual consolidated losses.
    • Separate return limitation year (SRLY).
    • Income tax treaty interpretations.
  • Represented a multinational technology company and its U.S. subsidiary in the acquisition of a Canadian lighting company and in the post-acquisition reorganization of the client's Canadian operating entities.
  • Represented the U.S. subsidiary of a publicly traded Mexican manufacturer in the tax-free restructuring of its U.S. subsidiaries.
  • Represented the U.S. subsidiary of a publicly held equipment rental company in an income tax audit involving a proposed adjustment of more than $160 million that resulted in a full concession by the IRS on the primary issues in dispute.

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