International Tax

Williams Mullen attorneys provide practical cross-border tax planning strategies on structuring U.S. owned investments in foreign markets. Our attorneys also provide comprehensive assistance with respect to International Estate Planning and Administration. We understand our client’s specific business goals and objectives as they expand on a global basis and guide them through the complexities of cross-border tax laws and relevant business issues. Whether you are at the start of a new foreign investment, planning additional foreign investments or desire to restructure and make it more tax efficient, our professionals tailor and employ business-driven structures and uncover planning opportunities that address your needs.

Outbound Tax Planning

Our U.S. Outbound tax planning strategies focus on number of factors that potentially impact foreign investment, including:

• Local country tax rules and comprehensive income tax treaties
• Client's foreign investment portfolio and foreign tax credits management
• Legal entity structure
• The need for a holding company
• Partnership planning
• Profitability and foreign loss planning
• Repatriation strategies
• Debt financing and restructuring
• Transfer pricing

Inbound Transactions

Our experienced international tax professionals assist clients in understanding and navigating through the complexities of U.S. tax laws impacting foreign-owned U.S. companies. Understanding that the U.S. tax regime can negatively impact non-U.S. companies, our professionals offer cross border tax planning strategies to the U.S. subsidiary and its foreign parent corporation in order to minimize their global effective tax rate while fulfilling their business needs. Our U.S. Inbound tax planning strategies focus on a number of factors that potentially impact U.S. investments, including:

• Tax rules of the foreign jurisdiction where the foreign corporation is located
• Foreign corporation’s other foreign investments and overall global tax position
• Foreign corporation's legal entity structure
• Need for a holding company
• Current and expected profitability of the foreign corporation and their U.S. investments
• Cash flow requirements of the foreign corporation and their U.S. investments (Repatriation Strategy)
• Current and planned debt financing for the foreign corporation and their U.S. investment(s)
• Activities, functions, and ownership risks of the U.S. investment (Transfer Pricing)

Cross-Border M&A Transactions

Williams Mullen attorneys represent purchasers, sellers, financing sources, management, and advisors in a wide variety of transactions, including equity and asset acquisitions of both entire companies and subsidiaries or divisions. Our multi-national M&A tax planning and compliance services include but are not limited to the following areas:

• Performing M&A tax due diligence
• Reviewing tax provisions in acquisition agreements
• Providing tax planning solutions in both the pre and post merger periods
• Advising on tax free and partially tax free acquisitive reorganizations
• Advising on tax divisive strategies including spin-offs, split-offs and split-ups
• Profitability and foreign loss planning
• Repatriation strategies
• Debt financing and restructuring
• Transfer pricing

International Estate Planning & Administration

• Estate Planning for U.S. and non-U.S. citizens 
• Supervision of offshore trusts and other entities; and
• U.S. reporting requirements related to offshore entities and investments