“The team is praised for its productivity and turnaround, with sources remarking: ‘They respond to queries in minutes.’”

- Chambers & Partners

International Tax

Ivins, Phillips & Barker is a recognized national leader in handling U.S. federal income tax issues involving both activities of United States taxpayers in foreign countries, and activities of foreign taxpayers in the United States. Our firm serves individuals and corporations throughout the United States and all over the world. 

Our international tax attorneys have mastered all areas of international business taxation, including foreign acquisitions, dispositions and multinational restructurings, joint ventures, tax planning for intangibles, including issues relating to the international licensing of intangibles and international intangible structures, use of hybrid entities, intercompany transfer pricing (including negotiating advance pricing and competent authority agreements), income sourcing, foreign tax credits, allocation and apportionment of deductions, dual consolidated losses, sub part F, income tax treaties, and foreign currency transactions.  The lawyers within our international group are involved in analyzing these issues in connection with tax planning transactions and in tax controversies with the Internal Revenue Service.

Our international tax attorneys also regularly advise U.S. and non-U.S. high net worth individuals in connection with U.S. tax issues, including issued relating to business planning for inbound and outbound investment, expatriation, residency and related treaty issues, and participation in the Internal Revenue Service Voluntary Compliance Program, especially in relationship to complying with U.S. foreign bank account reporting rules.

In addition to our talented team of attorneys, we have access to an extensive network of leading firms and practitioners around the world. We are able to call upon the expertise of these colleagues at any time, in order to respond quickly to our clients' needs. Our clients include United States and foreign multinational corporations.

Representative Experience

  • Structuring multinational corporate structures for publicly traded and private companies, including coordination of tax advice with local counsel
  • Assisting French multinational in connection with reorganization of U.S. corporate structure
  • Advising private textile company in connection with intercompany transfer pricing, including preparation of associated transfer pricing study
  • Representing publicly traded multinational video game company in all aspects of international licensing of intellectual property, including U.S. federal income tax aspects of related income and expense
  • Representing publicly traded multinational entertainment company in competent authority request regarding intercompany royalties.
  • Representing publicly traded multinational company in connection with dual consolidated loss issues relating to its international tax structure
  • Assisting U.S. insurer in connection with planning for offshore structured settlement arrangements
  • Assisting Japanese multinational computer company in negotiating renewal of Advance Pricing Agreement
  • Assisting multinational auto company in connection with audit issues relating to implementation of its Advance Pricing Agreement
  • Representing several individuals in connection with Internal Revenue Service voluntary disclosure program as it relates to disclosure of foreign bank accounts
  • Representing U.S. real estate fund in connection with fund structuring for non-US and tax exempt investors
  • Representing U.S. publicly traded brokerage in connection with U.K. acquisition
  • Representing Europe based broker-dealer in connection with structuring U.S. activities, including transfer pricing aspects
  • Representing U.S. indivdual in connection with "passive foreign investment company" (PFIC) issues in connection with a multi-million dollar disposition of shares of a non-U.S. company
  • Representing non-US person in connection with expatriation issues under Section 877 of the Internal Revenue Code
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