Advisory First, Not Compliance-Led

Most firms approach US corporate tax from the compliance end: file what happened last year, then move on. We work the other way around. We start with where the business is going — reinvestment, expansion, flotation, trade sale — and build the tax structure to match.

That distinction matters most in the choices that are expensive to unwind later. Should a growing business operate as a US corporation at the 21% corporate rate, or as a pass-through where individual rates reach 37%? Where should debt sit in an acquisition? How should intellectual property be held, licensed, and developed? These questions decide the real tax cost of a business over a decade, and they need to be answered at the beginning, not discovered at the end.

Who We Advise

Corporations. Entity classification elections, US federal and state tax planning, inter-company charges, cash repatriation, and structuring inbound or outbound expansion.

Partnerships. Partnership structures remain some of the most flexible and most misunderstood vehicles in US tax. We advise on formation, profit allocation, carried interest structures for fund managers, and the disposal or restructuring of partnership interests.

Trusts. US tax treatment of trusts — particularly foreign trusts with US beneficiaries or grantors — is unforgiving when handled badly. We advise trustees and families on classification, reporting, and distribution planning across borders.

Entrepreneurs and owner-managed businesses. From choice of entity at formation through to exit, we act as the US tax advisor in the room when small business entrepreneurs make their biggest decisions: raising capital, expanding abroad, bringing in partners, or selling.

Cross-Border Corporate Tax Is Where We Live

Plenty of firms offer corporate tax advice within the US. Far fewer can handle the moment a business crosses a border — a European company expanding into the US, or an American business establishing itself in France, the UK, or elsewhere in Europe.

That cross-border layer is our specialty. We advise on US withholding tax and the treaty network that can reduce it, controlled foreign corporation and PFIC exposure, debt-versus-equity financing of US operations, transfer pricing-sensitive inter-company arrangements, and the 15% FIRPTA withholding on disposals of US real property interests.

Led by Ed Rieu, a US-qualified lawyer with decades of experience on the US tax desks of global accounting firms, we’ve advised businesses ranging from technology manufacturers and luxury goods houses to private equity funds, hedge funds, and family-owned groups.