Practice Chair(s)
With the support of Chamberlain Hrdlicka’s international practitioners, borders are transformed from formidable barriers into gateways of opportunity for our clients.
Overview
International Tax
International Transactions
Modern-day realities require many businesses and wealthy individuals to operate far beyond their countries of origin. With the support of Chamberlain Hrdlicka’s international practitioners, borders are transformed from formidable barriers into gateways of opportunity. We handle all elements in the international arena: outbound planning for U.S.-based clients; inbound planning for foreign clients; cross-border business support and counsel; personal planning for “citizens of the world”; resolving tax controversies involving international issues.
The global economy has opened a new world of opportunities and challenges for all types of businesses, many of which had never before considered themselves “international.” The new opportunities of the world marketplace can be clouded by complexities and dangers, from the possibility of overlapping taxation to both the unfamiliarity – and sometimes unreliability – of foreign legal systems as well as the constant change in U.S. immigration laws. This applies as much to non-U.S. companies coming to the United States as it does to U.S.-based companies going abroad.
Whether it involves designing a structure for a long-term presence in the U.S. or abroad, or negotiating a distribution or joint venture agreement for a particular project, we provide full legal support to help the client proceed with confidence. We offer a depth of tax knowledge that few others can match, and we back it up with skills in U.S. immigration laws and intellectual property.
Broad-Based Resources For International Challenges
Our attorneys work with U.S. companies and advise them on how to best structure an interest or participation in a foreign venture or investment. We also advise foreign clients on ways to structure their investments and business ventures in the United States and obtain appropriate U.S. immigration visa status.
International Resources for the Individual
“International” no longer means just business; it also includes personal estate and tax planning for individuals whose portfolios of assets and investments are no longer limited to one country. Clients who benefit from our services include foreign individuals investing in the United States, and U.S. individuals investing abroad. In fact, many of our clients are families whose members live both within and outside the United States, and whose investments and businesses are on both sides of the border. For these clients, planning does not stop at any border or with any transaction, but extends to all aspects of the family and its enterprises.
Foreign individuals enlist our aid with personal planning, with foreign and domestic trusts often playing a significant role in our efforts. We handle immigration and visa processing, and we assist individuals with pre-immigration tax planning to minimize the impact of income, estate and gift taxes. If tax controversies arise, we then combine our international tax knowledge with our tax controversy capabilities to defend tax reporting positions involving international issues.
Areas of Expertise
- Minimizing tax costs on international operations by optimizing use of the foreign tax credit and international tax treaties.
- Maximizing tax deferral opportunities for foreign corporations by navigating the complex restrictions of subpart F, passive foreign investment company rules, and foreign personal holding company rules, among others. We work to minimize the effective tax rates that apply under foreign tax laws in order to create or maximize deferral possibilities.
- Taking advantage of export incentives such as the interest-charge DISC or the foreign sales corporation.
- Selecting the proper entity working with the sourcing rules to minimize or eliminate U.S. taxation on in-bound ventures, including branch profits tax.
- Structuring transactions and entities to minimize the adverse impact of FIRPTA rules that apply to foreign investments involving U.S. real estate.
- Minimizing the impact of complex U.S. transfer pricing rules that apply to transactions between related parties.
News
News
- Chamberlain Hrdlicka to Sponsor and Shareholders to be PanelistsOctober 29, 2024
- Philadelphia-based Shareholder Kevin Sweeney Shares Insights in Tax Notes ArticleOctober 11, 2024
- Atlanta Office a Top Workplaces 2024 HonoreeAugust 20, 2024
- Chamberlain Hrdlicka’s Houston Tax Practice Shortlisted as Tax Firm of the YearAugust 8, 2024
- Patrick W. Martin Quoted in Tax Notes Article on The IRS and Treasury Proposed Regulations on Foreign Trust and Foreign Gift and Bequest TransactionsJune 4, 2024
- Jaime Vasquez quoted in a Law360 article about becoming Head of Chamberlain's San Antonio OfficeApril 23, 2024
- New Managing Shareholder of Chamberlain Hrdlicka San Antonio Office NamedApril 22, 2024
- Kevin Sweeney in The New York TimesMarch 9, 2024
- San Antonio Business Journal includes Chamberlain Hrdlicka in 2024 Largest Law Firms ListJanuary 29, 2024
- Atlanta Shareholder Hale Sheppard Named Forbes ContributorJanuary 23, 2024
- Patrick W. Martin and Leo Unzeitig Represent Taxpayer Who “Scores Big Win in FBAR Dispute”November 22, 2023
- Patrick Martin and Daniel Silva analyze fraud loopholes in the Foreign Account Tax Compliance Act (FATCA), propose a new government framework to address international tax fraudOctober 25, 2023
- In Tax Notes International cover story, Patrick Martin, Sebastien Chain and Luz Villegas-Banuelos examine three recent taxpayer victories in precedent-setting international information reporting cases: Aroeste, Bittner, and FarhySeptember 20, 2023
- Jeff Luechtefeld’s recent podcast interview, “The IRS and Rules About Rules with Jeff Luechtefeld,” on the Emerging Litigation PodcastSeptember 6, 2023
- Chamberlain Hrdlicka’s continued growth in Texas drives strategic office renovations in Houston and San AntonioAugust 4, 2023
- Chamberlain Hrdlicka's San Antonio Office expands space and updates officesAugust 1, 2023
- Legal 500 ranks David Aughtry and Larry Campagna in its Hall of Fame, Jaime Vasquez and Juan Vasquez Jr rank as Leading Lawyers in US: Tax Contentious CategoryJune 12, 2023
- Kevin Sweeney quoted in Tax Notes articleTax Notes, June 1, 2023
- Ryan Carlock and Sean Gannon are focus of Law360 Pulse article on joining Chamberlain HrdlickaLaw360, February 17, 2023
- Houston Business Journal’s 2022 Best Places to Work includes Chamberlain Hrdlicka in Top 10November 1, 2022
- Chamberlain Hrdlicka Reception Hall debuts at University of Houston Law CenterSeptember 21, 2022
- 2022 Texas Super Lawyers includes Chamberlain Hrdlicka AttorneysSeptember 21, 2022
- Houston Business Journal (HBJ) includes Chamberlain Hrdlicka in 2022 Best Places to WorkSeptember 15, 2022
- Texas Lawyer article highlights the firm’s growth in San Antonio as Patrick Martin, Anuar Estefan and Luz Villegas-Bañuelos join Chamberlain HrdlickaSeptember 2, 2022
- Chamberlain Hrdlicka announces the addition of three attorneys to the firm’s San Antonio officeSeptember 1, 2022
- Atlanta attorneys voted for Hale Sheppard as 2023 Lawyer of the Year in Tax and Tax Litigation and Controversy through US News' Best Lawyers in America®August 18, 2022
- Legal 500 rankings for Chamberlain Hrdlicka as a Top Tax Law Firm and Adds to Individual Ranks in 2022June 17, 2022
- David Aughtry, Stephanie Friese Aron, Seth Price, Hale Sheppard, Erica Opitz, John Kirbo, John Guin, and Barclay Taylor named as Georgia Super Lawyers, Rising StarsFebruary 15, 2022
- Kevin Sweeney is spotlighted in Bloomberg TaxBloomberg Tax, November 5, 2021
- Zack Anderson, Brent Bartlett, Gabriella Cole, Jamihlia F. Johnson and Peter D. Rehm join Chamberlain Atlanta OfficeMay 4, 2021
- Law360 Tax Authority International Advisory Board elects Hale Sheppard to the BoardLaw360, April 23, 2021
- Chamberlain Attorneys present Webinar on Tax Traps and Employment Law Considerations of a Remote WorkforceMarch 23, 2021
- Two Philadelphia Attorneys elevated by Chamberlain HrdlickaMarch 2, 2021
- Five Attorneys elevated at First Virtual Shareholders MeetingMarch 2, 2021
- Jeffrey Luechtefeld elevated to Shareholder by Chamberlain HrdlickaMarch 2, 2021
- Super Lawyers names Chamberlain Hrdlicka attorneys as 2021 Georgia Super Lawyers and Rising StarsFebruary 12, 2021
- Virtual This Year! Chamberlain Hrdlicka Virtual Annual Tax and Business Planning Seminar is November 10-12, 2020November 10, 2020
- Three Attorneys join Chamberlain Hrdlicka Atlanta Office's Tax Controversy and Litigation PracticeNovember 10, 2020
- August 13, 2020
- Sebastien Chain, Justin VandenBout and Jaime Vasquez named 2020 Rising StarsMarch 10, 2020
- 2020 Georgia Super Lawyers and Rising Stars Named at Chamberlain HrdlickaMarch 4, 2020
- February 13, 2020
- October 30, 2019
- March 26, 2019
- December 13, 2018
- June 2009
- June 2008
- Daily Tax Report, May 2008
Presentations
Seminars & Presentations
- Panelist: Tax Enforcement of the Global Taxpayer: Crossing the LineAnaheim, California, November 8, 2024
- Panelist: US Planning Structures for Foreigners That Take Into Account Foreign Tax LawAnaheim, California, November 7, 2024
- Panelist: Tax Treaties for the Wealth Transfer ProfessionalWaikiki, Hawaii, November 5, 2024
- International Tax Group Meeting 2024San Antonio, Texas, May 23, 2024
- Chamberlain Hrdlicka will host the Laredo Tax and International Business Planning Seminar at the Laredo Country Club on November 16, 2023Laredo Country Club, 1415 Country Club Drive, November 16, 2023
- Chamberlain Hrdlicka Annual Tax and International Business Planning Seminar will present a variety of important and timely topicsEstancia del Norte Hotel, 37 NE Loop 410 at McCullough, November 8, 2023
- Chamberlain Hrdlicka Annual Tax and Business Planning Seminar will present a variety of important and timely TopicsThe Houstonian, 111 North Post Oak Lane, November 1, 2023
- Chamberlain Hrdlicka Brownsville Tax and International Business Planning Seminar at the Rancho Viejo Resort & Country Club on May 25, 2023May 25, 2023
- The University of San Diego School of Law & Chamberlain Hrdlicka International Tax Institute in Mexico City on May 5, 2023Club de Industriales A.C. Mexico City, May 5, 2023
- Chamberlain Hrdlicka attorneys speak at the 2023 Houston CPA Society Tax ExpoSugar Land Marriott Town Square, Sugar Land, TX, January 9, 2023
- The Houstonian on October 27, 2022
- 43rd Annual Tax and Business Planning Virtual Seminar is on November 2-4, 2021November 4, 2021
- November 10, 2020
- The Continuing Role of the Fifth Amendment Protections in Tax Enforcement36th National Institute on Criminal Tax Fraud & 9th Annual National Institute on Tax ControversyLas Vegas, NV, December 12, 2019
- Tax Regulatory Update, Process and Potential Questions Regarding ValidityDeloitte Tax Global Tax Planning ConferenceVillanova, PA, November 21, 2019
- Norris Conference Center at City Centre, October 30, 2019
- 33rd Annual National Institute on Criminal Tax Fraud and 6th Annual National Institute on Tax ControversyLas Vegas
- October 19 to 23, 2015
Publications
Publications
- Philadelphia-based Shareholder Kevin Sweeney and Associate Katherine Wheeler Published in The Legal IntelligencerNovember 7, 2024
- Shareholder Patrick W. Martin and Associate Luz Villegas-Bañuelos Published in Tax NotesNovember 4, 2024
- Special Counsel Mark Lubin Published in The Legal IntelligencerOctober 31, 2024
- Mark Lubin Published in PICPA CPA Now BlogJune 26, 2024
- Kevin Sweeney Article Published in The Legal IntelligencerJune 24, 2024
- Mark Lubin Published in The Legal IntelligencerJune 11, 2024
- Mark Lubin's article "Considerations in Conducting Tax Due Diligence in Business Acquisitions,” in The Legal IntelligencerThe Legal Intelligencer, May 1, 2024
- Mark Lubin's article "Tax Treatment of Partnership and Their Partners—Are Rough Times Ahead?,” in The Legal IntelligencerThe Legal Intelligencer, January 16, 2024
- Jeff Luechtefeld’s article, “Procedural Challenges to IRS Compliance With the APA and Its Impact on Tax Litigation,” in the summer issue of Journal of Emerging Issues in LitigationJournal on Emerging Issues in Litigation, July 5, 2023
- Kevin Sweeney's article, “The IRS to Scrutinize ERC Claims: Are Businesses Ready?” in CPA NowCPA Now, July 3, 2023
- Article by Kevin Sweeney on “There’s Still Time for Businesses to Claim Employee Retention Credits but They Must Be Vigilant”The Legal Intelligencer, May 25, 2023
- Mark Lubin and Phil Karter’s article, “Poor Communication Practices Can Endanger Confidentiality Privilege,” in PICPA’s CPA NowCPA Now, the blog of the Pennsylvania Institute of Certified Public Accountants, February 7, 2023
- Mark Lubin's article “Tax Pitfalls Associated with Closely Held Businesses”Pennsylvania CPA Journal, September 15, 2022
- Jeffery Luechtefeld’s article “Preparing to navigate IRS appeals: Strategies for tax practitioners”September 7, 2022
- Mark Lubin article on "Avoiding Errors In Establishing Basis In Business Interests"Pennsylvania CPA Journal, Spring 2022
- Mark Lubin article on "Common Errors in S Corp Taxes"CPA Now, March 16, 2022
- Article by Kevin Sweeney on “COVID-19-Related Government Budget Deficits May Spur Aggressive Payroll and Sales Tax Audits”Modern Restaurant Management, August 10, 2020
- Texas Lawyer, March 28, 2019
- Intellectual Property Magazine, February 13, 2019
- Expat Network, September 2018
- AICPA Practical Tax Strategies, April 2018
- Tax Notes, September 11, 2017