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International Tax Group

The International Tax Group at Jeffer Mangels Butler & Mitchell LLP (JMBM) advises foreign and domestic businesses and their owners on all aspects of ownership structure, operations, foreign tax credits, cross border transactions, and coordination of tax systems and treaties in various jurisdictions to achieve solutions that are globally tax-efficient. Our tax expertise combined with JMBM's extensive knowledge in intellectual property, corporate law, real estate, hospitality, government relations, criminal law, health care, patent litigation, and labor and employment puts the Firm in a unique position to advise clients on substantially all aspects of international transactions.

The International Tax Group represents transnational families, high-net worth individuals, foreign corporations, trusts and other entities from numerous countries around the world with the goal of increasing tax efficiency and preserving global wealth. We understand that each individual, family or business owner has unique issues and specific objectives. The International Tax Group possesses special expertise and experience in developing strategies that meet these objectives and interests.

International Estate Planning

We assist our clients in all aspects of international estate planning. We advise clients on both inbound and outbound transfers of wealth and help them navigate the complex U.S. tax laws, including the U.S. estate tax and estate tax residency status. We counsel families that may have U.S. resident and nonresident status or citizenship in multiple countries. We understand the delicate, personal nature of designing an estate plan that affects living generations residing in multiple countries, as well as future generations. Estate plans are always based on confidential interviews with our clients. Each plan is drafted to meet a family's specific objectives in a manner that minimizes estate, gift and income taxes.

International Business and Tax Representation

We counsel our clients on a wide range of international business and taxation issues.

  • Selection of entities for foreign investment in the United States and U.S. and foreign entity classification.
  • All aspects of ownership and operation of U.S. real estate investments.
  • Advice regarding U.S. residency status for U.S. income and estate tax purposes.
  • Use of tax treaties and foreign tax credits to reduce overall worldwide effective tax rates.
  • Structuring international operations of domestic and foreign corporations, including intercompany pricing issues.
  • Corporate acquisitions, reorganizations, liquidations and financings in multi-jurisdiction transactions.
  • Unitary taxation issues involving multinational corporations.
  • Advice on reduction or avoidance of U.S. Federal and state withholding and employment taxes on earned income.
  • We have represented clients in criminal tax and civil investigations, Mutual Legal Assistance Treaty Requests, Letters Rogatory. extradition requests, and tax amnesty applications.

We also represent numerous U.S. individuals and companies who conduct business in other parts of the world. We advise these domestic clients on the most tax efficient way to organize their international operations.

Foreign Bank Account and Asset Reporting

JMBM has developed specialized expertise in helping clients report their foreign accounts and assets as is now required under Foreign Account Tax Compliance Act and foreign bank account reporting. JMBM's approach is to develop practical solutions for our clients to avoid or minimize civil and criminal penalties for failure to report such assets, and to provide clients with alternatives and options to preserve their wealth and begin complying with U.S. reporting requirements. We have successfully assisted many clients to obtain protection from income tax and penalties by navigating the Offshore Voluntary Disclosure Initiatives and recently created Streamlined Procedures.

Tax Controversy

Few requirements can be as intimidating as appearing before the Internal Revenue Service, the Franchise Tax Board, the Board of Equalization or the Employment Development Department in connection with audits of Federal and State income taxes, State sales and use taxes and employment taxes. JMBM's attorneys have successfully represented domestic and international clients in these proceedings. Our capabilities, experience and record are exemplary. We represent taxpayers on their own behalf in addition to other individuals in connection with their potential liability as a "responsible person" for unpaid trust fund liabilities, such as payroll and sales taxes. We have substantial experience with IRS/CID interviews, domestic and international criminal investigations, matters before the U.S. Department of Justice Tax Division Criminal Enforcement Section, Grand Jury investigations, and various U.S. Attorney's Offices.

We represent clients accused of tax evasion or filing false returns, failure to remit employment taxes, failure to file returns, obstruction, tax shelter promotion, Klein conspiracies, perjury and bank secrecy matters.

Commercial Real Estate

The International Tax Group and JMBM's real estate lawyers specialize in the ownership structure, purchase, financing, leasing, development, management, and operation of commercial real estate investments for our international clients. We advise clients on the Foreign Investment in Real Property Tax Act (FIRPTA) in order to meet all tax withholding obligations and to provide solutions to mitigate the burdens imposed by FIRPTA. Additionally, JMBM's lawyers actively represent real estate investors and developers who are raising capital for acquisition and development of U.S. real estate projects through the EB-5 Immigrant Investor Program and U.S. securities markets.

Luxury Home Group

Whether you are buying, selling, financing, remodeling, building, designing, leasing – or involved in a dispute – no other real estate matter is quite as important as the one that involves your home, or the home of your client. The lawyers at JMBM have the experience and skill to advise, support and protect your rights, every step of the way. We help get the job done quickly, correctly and within budget. While your JMBM lawyer will be your one point of contact on all matters, the Group's outstanding attorneys have deep experience in all relevant areas of the law, and are available to quickly and effectively respond to your needs, no matter where in the world the residence is located.

Worldwide Legal Services - Interlaw

Through JMBM's membership in Interlaw, an international association of independent law firms in major world centers, our reach and ability to service clients extend beyond the borders of the United States to the rest of the world. Interlaw comprises some of the most well-established premier law firms in their respective locations. The many advantages of our relationships with these law firms in more than 60 countries directly benefits many of our multinational clients and enables us to find global solutions by coordinating various tax regimens and laws for globally tax-efficient structures.

Our Commitment

The lawyers of JMBM’s International Tax Group are committed to solving international tax problems and assisting our multi-cultural clients in achieving their world-wide goals. We invite you to contact us to discuss how we can help.