With the support of Chamberlain Hrdlicka’s international practitioners, borders are transformed from formidable barriers into gateways of opportunity for our clients.
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.
- Sean Gannon’s arrival to the firm was highlighted in the article in the Daily ReportThe Daily Report, March 1, 2023
- Ryan Carlock and Sean Gannon are focus of Law360 Pulse article on joining Chamberlain HrdlickaLaw360, February 17, 2023
- Sean Gannon joins Chamberlain Hrdlicka Atlanta OfficeFebruary 14, 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
- International Tax Attorney Patrick W. Martin and Two Associates join Chamberlain Hrdlicka’s San Antonio OfficeChamberlain Hrdlicka announces the addition of three attorneys to the firm’s San Antonio officeSeptember 1, 2022
- Hale Sheppard recognized as Lawyer of the Year in Tax and Tax Litigation and Controversy in Atlanta by Best Lawyers in America®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
- Jeffrey Luechtefeld elevated to Shareholder by Chamberlain HrdlickaMarch 2, 2021
- Two Philadelphia Attorneys elevated by Chamberlain HrdlickaMarch 2, 2021
- Five Attorneys elevated at First Virtual Shareholders MeetingMarch 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
- Chamberlain Hrdlicka to Host 42nd Annual Houston Tax and Business Planning Seminar on October 30th at Norris Conference Center at City CentreOctober 30, 2019
- March 26, 2019
- December 13, 2018
- June 2009
- June 2008
- Daily Tax Report, May 2008
Seminars & Presentations
- 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
- 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
- When Keeping Investments in Offshore Insurance Wrappers Goes Wrong: The Tax Risks and Benefits of Offshore Private Placement InsuranceAICPA Practical Tax Strategies, April 2018
- Tax Notes, September 11, 2017
- Tax Alert: IRS Announces Unprecedented Waiver of Penalties for Certain International Information Reporting and Late Tax Returns: Short Window of OpportunityBusiness and International Tax Blog, August 29, 2022