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
- 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!