Case Studies

We acted for an Asian group of individual and corporate investors who purchased a real estate development project in the United States. The assignment included designing a structure that was tax effcient in both the United States and the investors’ home jurisdiction as well as undertaking routine compliance work for over 10 years on this structure.

We acted for a U.S. citizen resident in Europe in arranging his affairs to take advantage of treaty benefits in a variety of jurisdictions and to minimize local tax on the client’s operations. The assignment has included creating foreign companies and providing local directors and compliance work in the various jurisdictions.

We acted for a U.S. resident who owned property in Europe and conducted business operations throughout the Scandinavian countries. The assignment required liaising with accountants and lawyers in several countries and creating and overseeing the operations of companies in these jurisdictions.

We acted for a U.S. citizen resident in France and successfully brought a refund action against the United States overturning the I.R.S.’s initial position that certain French taxes were not creditable under the applicable U.S. foreign tax credit rules.

We acted for a U.S. citizen resident in the United Kingdom who had excess foreign tax credits. By utilization of certain differences in the treatment of pensions in the United States and the United Kingdom, we were able to maximize the client’s current after-tax income while at the same time increasing his pension allowances.