We possess extensive experience in international tax, foreign residence status and cross-border transactions.

We are also experienced in US tax law, particularly the world-wide obligation of US citizens to pay US tax, regardless of their permanent residence.

In relation to UK tax law, we have a wealth of knowledge of UK inheritance laws.

We frequently liaise with the Internal Revenue Service (IRS) and HM Revenue and Customs Service (HMRS) on behalf of our clients.

All of our senior advisers are former ATO managers and have been directly involved in treaty negotiations, CRCs, tax havens, complex corporate structures involving offshore entities and the use of offshore trusts.

We provide specialised international tax advice on:

• Corporate restructuring
• Controlled Foreign Companies (“CFC”) and Foreign Investment Funds (“FIF”) issues for overseas companies and trusts controlled by Australian Residents;
• Foreign trusts with Australian beneficiaries;
• Transfer Pricing
• Thin capitalisation;
• Foreign tax credit;
• Withholding tax; and
• Double tax agreement issues