International Taxation

For companies doing business internationally, effective tax strategy can make all the difference in the world. Sound tax planning can save a global business millions of dollars while at the same time ensuring full compliance with applicable laws to avoid legal headaches down the road. Because international tax law varies widely depending on jurisdiction and is always subject to change, it is crucial to engage counsel who fully understand the tax implications of international operations.

Jackson Walker attorneys have the experience, knowledge and relationships to help our clients thrive in the international business arena. We work with clients ranging from high net worth individuals wishing to diversify their holdings and enhance economic returns to Fortune 500 corporations conducting business in multiple jurisdictions. We are particularly experienced in helping middle market clients develop innovative strategies to profit internationally, and we have extensive experience in both inbound and outbound investments. A few examples of the international tax services we provide include:

Inbound: A variety of factors make Texas an attractive location for international investment, and we have helped some of the most influential foreign investors and companies establish operations here. Our extensive experience enables us to counsel our clients as to the most tax-efficient methods of investing in or establishing U.S. operations, taking into consideration all applicable tax treaties.

Outbound: We have helped clients develop tax-efficient strategies for establishing foreign operations, including the creation of offshore corporations, movement of U.S. personnel to foreign countries, and related issues. For some exporters, establishment of an Interest Charge Domestic International Sales Corporation (IC-DISC) can provide a significant tax benefit, and we routinely assist clients in forming this type of entity. For companies with operations in multiple jurisdictions, how and where those holdings are maintained can have significant tax consequences; we provide recommendations for creating structures that maximize efficiencies across jurisdictions.

Although we are rooted in Texas, we represent clients all over the globe. Our International practice group has transactional experience in over 85 jurisdictions. We have attorneys who are licensed in other countries and collectively speak more than 15 different languages.

Furthermore, as a founding member of Globalaw™, we are a part of a worldwide network of independent law firms with more than 4,500 lawyers in 160 cities around the world.

  • Represented client in the tax structuring and repatriation of terminating offshore fund.
  • Represented $1 billion distributor with the creation of offshore structure.
  • Represented large private domestic company with IC-DISC planning and utilization for private large domestic company.
  • Represented U.S. public company with tax corporate expatriation.
  • Represented investor in large offshore company with tax opinion regarding U.S. permanent establishment.
  • Represented client with the structure and sale of large offshore energy design firm valued at $100 million.
  • Represented controlled foreign corporation (subsidiary) and international sales company for multimillion-dollar heavy equipment dealer with extensive planning, with emphasis on international tax and treaty ramifications.
  • Represented several non-U.S. companies in connection with an IRS examination of their activities in the U.S. pursuant to IRS Industry Director’s Directive #1 – United States Outer Continental Shelf Activity, which provides notice and field direction about foreign taxpayers engaged in activities related to the exploration for, or exploitation of, natural resources on the Outer Continental Shelf in the Gulf of Mexico.

July 9, 2018
Speaking Engagements

Willie Hornberger Speaks at SelectUSA Investment Summit

Jackson Walker partner Willie Hornberger traveled to Washington, D.C., to share firsthand knowledge of tax regulation and policy at the 2018 SelectUSA Investment Academy.

August 28, 2017
Speaking Engagements

Jackson Walker Attorneys Speak on US-Mexico Relations at CPA Conference in Mexico

Immigration attorney James Prappas and tax attorney Willie Hornberger traveled to Monterrey, Nuevo Leon, Mexico where they gave separate presentations at the Programa General del 4Âş Congreso Internacional of the Instituto de Contadores PĂşblicos de Nuevo LeĂłn A.C (ICPNL), an organization of certified public accountants in Nuevo Leon.

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