International Tax Planning

Our lawyers have in-depth expertise in international tax planning for both U.S. and non-U.S. based companies. We develop tailored, tax-efficient structures that help meet our clients’ commercial goals. To address tax issues involving multiple jurisdictions, we rely on our own experience, and on our network of correspondent firms (including top tax advisory firms in each country) or on our clients’ regular foreign advisors. Covington is a proud member of the Taxand network, the world's largest independent organization of tax experts with more than 700 tax partners and over 3,000 tax advisors in 48 countries.

Capabilities

• Tax efficient restructuring of international operations, including to address implementation of the global minimum tax under the OECD’s Pillar 2 Project as well as other non-U.S. tax developments
• Strategic advice in connection with cross-border acquisitions and dispositions to align these transactions with a company’s global tax planning
• Foreign tax credit planning for U.S. multinationals, including the creditability of novel foreign taxes and the availability of the foreign tax credit limitation based on sourcing of income and expense allocation
• Subpart F planning to address complex global manufacturing, including supply chain planning
• Inbound structuring in connection with investment in new and expanded U.S. operations, including debt funding and licensing of related intellectual property
• Advice concerning U.S. income tax treaties, including qualification under the relevant limitation on benefits provisions, avoiding the creation of a permanent establishment, and obtaining reduced withholding taxation on outbound payments