Hill Smith has a strong reputation for its focus on international tax matters. Our Taxation practice covers the range of all international business activities and taxes. We provide ongoing advice to multinational businesses concerning all U.S. federal income tax rules relevant to foreign operations, as well as specific advice concerning foreign taxation, with a particular focus on the countries of the European Union. We advise from the inception of business operations in a foreign country to the disposition of a business.
We work extensively with our clients on overseas business structures for start-up operations. This includes structuring distribution and purchase arrangements overseas. We advise concerning structures of sales and manufacturing operations in foreign countries and operations. We structure operations throughout the world, with a particular emphasis on the European Union countries. We also have substantial experience in structuring operations in Asia, the Middle East and South America.
We are also frequently called upon to structure and negotiate acquisitions and dispositions by multinational companies, planning for the most tax-efficient structures from both non-U.S. and U.S. business and tax viewpoints. Typical issues include stock versus asset purchases, manner of ownership and the form of business entity.
In today’s fast moving business environment companies may be motivated to reorganize their worldwide tax and legal structure for a variety of reasons. For instance, through a strategic merger or acquisition, or to realign a worldwide structure in order to effectuate a strategic spin-off, listing, divesture of business operations. This can involve sizing down a business, changing the country of operation or converting to a pass-through entity to obtain benefit of foreign losses.