Many tax practitioners have clients residing or working in the United States who are not U.S. citizens, or individuals who are are working outside the United States. Some clients may own or control foreign corporations which conduct business throughout the world. These clients face complex issues that the practitioner must recognize and address, such as the tax consequences of:

• Taxation and withholding of foreign nationals working in the United States, including entertainers, performers, attorneys and other professionals
• Taxation and withholding of foreign nationals investing in the United States
• Taxation of U. S. citizens and residents living and investing in foreign countries
• Taxation of professionals working in several states or countries, including athletes, musicians, entertainers and artists
• Taxation of U. S. shareholders who own controlled foreign corporations
• Foreign Sales Corporations and Interest Charge DISC Corporations
• Transactions between the client and its foreign related party (see Transfer Pricing)
• Foreign Tax Credit issues
• Transfers to or from a foreign trust
• Gifts received from a foreign source

We'll advise you on the applicability of tax treaties as they relate to your client's specific tax issues. Mitchel Zuniga & Smith will render advice regarding any tax issue or financial transaction with international aspects or implications. Our specialists also accept speaking engagements to your business or professional group regarding any international tax issue.

Transfer Pricing
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