As one of the top international trade law firms, Kirton McConkie represents clients in international trade and transactions around the world. Our group of international lawyers assist clients with buying and selling goods by negotiating deals, drafting contracts, importing and exporting products through customs, registering and distributing goods and ensuring that products comply with applicable regulations, including regulations from the United States Food and Drug Administration.

If you are planning a cross-border operation or investment, you must work within the complex U.S. tax regime governing such transactions. Potential hidden pitfalls arise within the U.S. tax rules involving foreign transactions that could have long-term and significant consequences. Proper planning can help to protect your operations from these potential pitfalls while seeking to minimize your global effective tax rate (GTE).

In addition to our expertise in treaties on international trade agreements and sales, Kirton McConkie's international tax attorneys support clients in identifying applicable taxes for international transactions, including the application of tax treaties. We also actively assist clients with their planning and structuring to maximize the efficient use of foreign tax credits, tax deferrals, and the benefits of certain entity classifications -- including the use of blocker entities, IC-DICS and tiered structuring under the “check-the-box” regulations.

Examples include:

  • Direct Sales and Multi-Level Marketing:  We serve clients by establishing the legal transactions for direct sales and multi-level marketing. Client product lines include computer software, health and wellness, handbags, energy drinks and automotive products. From initial start-ups to $100 million multi-national publicly-traded companies, we work closely with each client to understand and adapt to the risks and nuances associated with this dynamic and growing business model. We represent clients in this industry all over the world, including Japan, Korea, Singapore, Hong Kong, EU, Canada, Russia, Ukraine, Mexico, Brazil, Puerto Rico, New Zealand and Australia.
  • International Business Transactions, Venture Capital, and Mergers and Acquisitions: We represent domestic and international clients with a broad range of business transactions throughout the world, including mergers and acquisitions, capital markets offerings, venture capital, project finance, securities compliance, corporate governance and other corporate activities.
  • Import/Export Business: We help our clients import products into and export products from the United States and other countries provide counsel on customs regulations worldwide.  For example, we have analyzed customs regulations in every country in South America to help multinational corporations set up distribution networks.
  • Private Client: Our attorneys plan for both foreign and domestic private clients with cross-border income, investments, trust and estate planning issues. Our attorneys have experience addressing complex tax issues involving foreign trusts and investment holding companies (CFCs/PFICs) as well as the formation of entity and fiduciary structures in offshore financial centers. Our attorneys are also heavily involved with the relocation of families to the U.S. and expatriation as well as other issues surrounding highly mobile individuals and families, such as foreign asset management, probate matters, real property and FIRPTA concerns. Kirton McConkie attorneys have experience assisting clients with U.S. tax controversies and other interactions with the Internal Revenue Service regarding their foreign investments and reporting obligations, including FBAR and FACTA and voluntary disclosure programs. 

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