Melinda Fellner Bramwit
Tax, Corporate, Trusts and Estates, Private Client, International, FinTech, Cryptocurrencies, and Blockchain
International Tax
The globalization of business has resulted in a need for experienced international tax advice. Seasoned advisors, who can identify international tax issues and structure international operations to minimize tax burdens, significantly enhance a multinational enterprise’s competitive edge in the global marketplace.
Rimon international tax attorneys have developed that experience in the course of assisting the United States and foreign-based multinational corporations, joint ventures, and individuals in the design and implementation of tax-efficient global finance, intellectual property, trading/distribution structures, and U.S./foreign tax audits and controversies. In the process, these attorneys have developed an extensive network of foreign counsel proficient in the tax laws of their respective jurisdictions.
Specific areas of substantive experience include:
- Subpart F and PFIC planning
- Cross-border transactional planning and structuring
- Mergers and acquisitions
- Joint venture structuring
- Choice-of-entity and entity classification
- Check-the-box planning
- Tax minimization strategies
- Foreign tax credit planning
- Dual consolidated loss planning
- Transfer pricing
- Electronic commerce issues
- FATCA compliance
- International estate planning
- IRS litigation and audits of nonresident U.S. citizens and multinational businesses
- Voluntary disclosures of noncompliant U.S. citizens and businesses
