International tax rules continue to evolve as businesses, investments and families become increasingly global. Cross-border structures often involve multiple tax systems, treaty provisions and anti-deferral rules that require careful interpretation beyond the domestic tax laws of any one jurisdiction.
We advise clients on complex international tax matters affecting cross-border investments, business operations and private wealth. Our focus is on providing practical, commercially aligned advice that supports informed decision-making across the United States, India, the UAE and other jurisdictions.
Treaty and Tax Advisory
Tax Treaty & Residency Advisory
International tax treaties and residency rules can significantly influence the taxation of cross-border income and investments. We advise on treaty interpretation, residency analysis, source, the foreign tax credit, withholding, and eligibility for treaty benefits across multiple jurisdictions.
International Anti-Deferral Regimes
Cross-border structures can pull in anti-deferral rules such as CFC, Subpart F, PFIC, and net CFC tested income (NCTI, the renamed GILTI regime), which can tax foreign earnings before any cash is distributed. We advise on what is caught, the elections available, including QEF and mark-to-market for PFIC holdings, and on restructuring to step outside a regime where that is possible.
Permanent Establishment & Cross-Border Business Taxation
Expanding into a new country can create tax obligations beyond the country of incorporation. We advise on permanent establishment exposure, business presence, and operating models that support international expansion without an unintended tax footprint.
International Tax Reviews & Regulatory Advisory
A structure should move with the law and the business. We review existing structures against the current rules, the treaties, and the post-2025 changes, including the NCTI and FDDEI redefinitions, identify exposures, and provide technical positions that support cross-border decisions.
How We Work
Every cross-border tax issue is read in its wider international context, weighing how domestic law, treaties and regulation interact. The work is partner-led: positions are stress-tested against the current rules, including the post-2025 changes, before we commit, with any US reporting kept consistent with the advice and coordinated with your return preparers.