International Tax
Ice Miller's International Group and Tax Group routinely provide advice to individuals and businesses that are subject to taxation by more than one jurisdiction and can assist with both individual and corporate tax planning and compliance, as well as issues arising out of decisions to relocate employees to other jurisdictions or hire foreign individuals in the United States.
Representative Experience
The following provides a sample of the international tax matters for which Ice Miller attorneys advise their clients on a daily basis:
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Restructuring of Worldwide Operations – Restructured entire worldwide activities and operations (including manufacturing, sales and offshore divisional headquarters activities) for US based publicly traded company in a tax-free manner using a variety of exchanges, contributions, liquidations and other techniques in 20+ countries.
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Rollup of Offshore Manufacturing and Sales Operations – Advised US based client on rolling up offshore manufacturing and sales activities and companies in connection with $150 million acquisition of US parent company.
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Domestic Operations of Non-US Based Parent Company – Organized and serve as outside counsel for US operations of multi-national manufacturing and sales company headquartered in Germany.
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Foreign Bank Accounts and Controlled Foreign Corporations – Advise clients regarding Foreign Bank Account Reporting and Controlled Foreign Corporation (CFC) disclosure and reporting obligations. Routinely assist clients regarding entering into IRS Voluntary Disclosure Programs and related US income tax matters.