Resident and Non-Resident Aliens, US Citizens Abroad and Expatriation

Coulter & Associates advises multinationals on the tax efficient structuring of cross-border transactions. In doing so we analyze and examine the income, gift and estate tax issues facing non-resident alien individuals investing in, or moving to the United States, and of United States persons investing or working abroad. The analysis includes specifically: residence, domicile, and situs issues, expatriation as a factor in estate planning, the income taxation of foreign trusts and their beneficiaries, including income tax rules on the residence of trusts; grantor trust rules applying to foreign and United States grantors; a comparison of trusts to other comparable foreign entities; grantor trust rules applying to foreign and United States citizens, such as stiftungs and anstalts; the problems of the multi-country estate and related issues. In conducting this work we frequently work with selected foreign law firms to assist us in these international matters.

INTERNATIONAL TAXATION

The Firm represents companies and individuals in international tax matters. These matters arise in the context of foreign entities and individuals investing or engaging in business in the United States, and United States entities or individuals with international operations. We regularly advise clients on issues such as FIRPTA, cross-border withholding taxes, tax treaties, foreign sales corporations, foreign tax credits, the branch profits tax, international reorganizations and business acquisitions and U.S. taxation of income earned through foreign corporations. We also work closely with foreign attorneys and accountants to provide complete tax and business advice to our clients.