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
- 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