Individual Taxation
In light of the growth of cross-border
investment and activities, individuals increasingly need the type
of sophisticated tax advice and assistance that previously only
multinational corporations needed. With international tax
authorities actively focusing on the investments and tax
liabilities of high-net worth individuals, individuals need to be
well-advised regarding the domestic and foreign tax consequences of
their investments and their activities.
We regularly advise individuals on the
domestic and foreign tax consequences of becoming a tax resident of
a foreign jurisdiction, including the tax treatment of compensation
earned outside of the individual’s home country. This advice
is also regularly provided to multinational corporations in
connection with determining their domestic and foreign withholding
and employment tax obligations.
We advise non-US persons with respect
to their investments and operations within the US, concerning their
US income tax (both at the federal and state levels) exposure,
minimizing the risk of being considered to be engaged in a US trade
or business; structuring investments in US real property; branch
profits tax issues; withholding tax issues; conduit financing
issues, earnings stripping and tax treaty implications.
In the UK we have particular expertise
in relation to advising individuals in relation to capital gains
tax planning on the sale of business assets including carried
interest structures for people working in the fund industry.
Indeed, due to the breadth of SNR Denton’s reach, we are able to
advise individuals who invest or operate in a multitude of
jurisdictions.
Areas of Focus:
- Form of investment
- Domestic tax issues
- Withholding and reporting
obligations
- Limiting foreign tax exposure
- Domestic tax consequences of foreign
investment
- Cross-border employment and other business
income