The challenge in cross-border work often lies not in a single rule, but in how two tax systems apply to the same facts, how those facts evolve as a business grows, and how filing and enforcement expectations shift over time. A structure that worked well at formation may need a different approach several years later.

We advise on inbound and outbound structuring, cross-border financing and intercompany arrangements, transfer pricing documentation, treaty positions, and the U.S. information returns that accompany foreign ownership. International matters make up about one third of our practice, with particular depth in U.S.–China work. We advise in English and Mandarin and deal directly with advisors in the client's home jurisdiction, so that tax, filing, and implementation decisions line up on both sides of the border.