Withholding Tax Advisory Attorney

Tax Representation in Washington DC

If you are a foreign corporation or individual investing in the United States or a U.S. company making payments to foreign persons, chances are the recently-issued U.S. nonresident alien withholding regulations affect you. These new rules are voluminous and complex, and the consequences for failure to comply with their substantive or documentation requirements may be harsh. The withholding rules cannot be considered in a vacuum; you also need to understand how they interact with tax treaty provisions and with various anti-abuse rules, such as the “conduit” regulations.

If you are a foreign corporation or individual investing in the United States, we can help you understand the rules, structure your investments to minimize or even eliminate withholding tax, fully benefit from the portfolio interest exception, utilize finance subsidiaries in treaty-favored jurisdictions to attract global investors, and satisfy the complicated documentation requirements.

If you are a U.S. withholding agent, we can help you comply with your withholding obligations and avoid liability.

  • Analyze how the withholding rules apply to your facts.
  • Structure your investments so as to eliminate or minimize withholding.
  • Analyze how treaties impact your withholding obligations.
  • Determine whether and how the conduit rules may affect your withholding obligations.
  • Ensure that you comply with relevant regulation requirements.
  • Negotiate Qualified Intermediary agreement with the IRS on your behalf.

Call Castro & Co. for legal representation from relentless and reliable tax attorneys - call (888) 595-5088! Serving Washington DC, Miami, Dallas and Orlando and clients all over the world.

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