International Tax

Alston & Bird has an extensive and diversified international tax practice covering all areas. Our attorneys provide tax advice on both inbound and outbound transactions, as well as tax advice in connection with managing global businesses. The mission of our international tax lawyers is to provide innovative solutions to appropriately minimize U.S. and foreign taxation.

Alston & Bird's international tax lawyers advise on transfer pricing, planning, tax provisions of agreements (including mergers, acquisitions and joint ventures), securing advance pricing agreements (APAs) and other rulings from one or more tax authorities, tax appeals under domestic procedures, securing competent authority relief and, if necessary, litigation of tax disputes. We help clients structure their holdings, transactions and business operations to create a tax efficient environment. We undertake legislative, regulatory and tax treaty advocacy when such approaches best serve our clients' objectives.

Alston & Bird maintains a close working relationship with tax experts in all major foreign jurisdictions. We use this network to provide efficient and responsive advice on matters of foreign tax law. In addition, we work with a client's existing foreign tax advisors as appropriate.

EXPERIENCE

• Cross-border acquisitions, dispositions, reorganizations, financings and joint ventures.
• Transfer pricing matters, including: development of pricing policies and methodologies; negotiation of APAs, including rollbacks and renewals; competent authority proceedings, including proceedings that have involved tax authorities of a dozen different foreign countries; and domestic dispute resolution proceedings.
• Financial transactions involving U.S. and foreign venture capital funds.
• Tax controversies, including examinations, private letter ruling requests, technical advice proceedings, IRS appeals, voluntary disclosure programs and litigation in all courts.
• Advice on all aspects of income tax treaties, including advocacy during the negotiation stage and ratification process, interpretation of treaty provisions and competent authority proceedings.
• Structuring inbound investments, including investment in U.S. real estate and real estate funds.
• Lobbying on international tax matters.
• Advice and counseling on the use of offshore insurance, captive insurance, reinsurance entities and life settlement transactions.

INNOVATION

We craft creative solutions to difficult problems in this very complex area. We have extensive experience in Europe, Asia, Canada and Latin America.  We have strong relationships—in some cases dating back decades—with leading tax advisors in the primary foreign jurisdictions. Our lawyers all possess expertise in general business income tax issues.

RECOGNITION

Alston & Bird’s international tax lawyers are widely recognized as experts in the field. Five of our lawyers are listed in The Best Lawyers in America. Our lawyers are leaders of the American Bar Association Tax Section committees that focus on international tax issues. Our group includes the chair of the Committee on U.S. Activities of Foreigners and Tax Treaties, a former chair of the Competent Authority Subcommittee of the Transfer Pricing Committee, the co-chair of the Subcommittee on Partnerships and Passthrough Entities of the Committee on Foreign Activities of U.S. Taxpayers, the vice chair of the Financial Transactions Committee and the former chair of the Committee on U.S. Activities of Foreigners and Tax Treaties. Our lawyers frequently publish in a wide range of journals, including The Journal of Taxation, The Journal of International Taxation and Tax Management International Journal. Our lawyers wrote the BNA Tax Management Portfolio, “Income Tax Treaties – Administrative and Competent Authority Aspects” and are the principal authors and editor of Practcial Guide to U.S. Transfer Pricing. Five of our lawyers are included in Euromoney’s Guide to the World’s Leading Tax Advisors, and our firm has consistently been rated by Euromoney as among the leading international tax practices in America. In fact, the tax practice of Alston & Bird was named by an International Tax Review poll as being among the world's leading tax planning and transactional practices.