Treaty-Based Corporate International Tax Planning

Washington DC & Miami Tax Attorneys

The large and growing U.S. tax treaty network makes it likely that your company is entitled to benefits under one or more of the 50-plus U.S. tax treaties. Understanding and working with these treaties requires experience, because notwithstanding efforts to conform to a model, U.S. treaties differ from each other in important, often subtle, respects. Even seemingly simple questions common to all treaties, such as who is entitled to treaty benefits, can give rise to contentious and potentially costly disagreements with the IRS. In fact, some tax treaties do not limit who is entitled to its benefits, which further facilitates planning.

Castro & Co.’s tax treaty practice covers both substantive legal issues and the administrative aspects of securing treaty benefits by filing appropriate forms or working with U.S. and foreign government officials. Our professionals are thoroughly familiar with nearly every U.S. tax treaties currently in effect, and we can work to ensure that our clients’ concerns are brought to the government’s attention during the treaty negotiation and re-negotiation processes through our alliance with a reputable lobbying firm in Washington, DC.

If you are operating in a foreign jurisdiction within the U.S. tax treaty network, Castro & Co. can help:

  • Ensure your eligibility for treaty benefits.
  • Structure your operations to maximize the value of treaty benefits.
  • Restructure your existing operations to avoid having a taxable permanent establishment.
  • Advise on treaty interpretation and the applicability of treaty provisions to your transaction.
  • Ensure that you satisfy any filing or information reporting requirements necessary to take advantage of treaty benefits.
  • Invoke the Competent Authority process under a treaty.
  • Make your concerns or the concerns of your industry known to the government officials who are negotiating or renegotiating a particular treaty.

Get the help you need at one of our offices in Washington DC, Miami, Dallas, or Orlando. We also serve clients all over the world. Call (888) 595-5088 for a free consultation today!

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