International Tax
Businesses and individuals with operations, investments, or family ties across borders face a tax landscape that grows more complex every year. Johnson Pope’s International Tax attorneys help closely held businesses, multinational companies, and high-net-worth individuals navigate U.S. and foreign tax rules with clarity and confidence — structuring transactions, entities, and cross-border investments in ways that are both tax-efficient and compliant.
Our attorneys regularly advise clients on the inbound and outbound tax issues that arise when a business grows beyond U.S. borders — from establishing foreign operations and structuring cross-border transactions to managing the reporting and compliance obligations that come with international activity. We work closely with our Corporate, Mergers & Acquisitions, and Trusts & Estates teams to make sure the international tax strategy supports the client’s broader business and personal goals, not just the transaction in front of us.
Areas in which our international tax attorneys apply their expertise include:
- Inbound and outbound tax planning
- Cross-border mergers, acquisitions, and joint ventures
- Foreign investment in U.S. real estate and businesses (FIRPTA)
- Committee on Foreign Investment in the United States (CFIUS) matters
- Structuring foreign subsidiaries, branches, and joint ventures
- Transfer pricing considerations
- Tax treaty analysis and application
- Controlled foreign corporation (CFC) and Subpart F/GILTI planning
- Foreign tax credit planning
- Expatriation and pre-immigration tax planning
- International estate and succession planning
- FBAR and foreign asset reporting compliance (FATCA)
- Voluntary disclosure and international tax controversy
