We resolve U.S. tax issues for cliens with U.S. tax duties and connections in Germany, Austria, Switzerland, and other countries. If you have recently been contacted by your bank about the need to file a return with the IRS, we can help.

International Tax Planning

For corporations, tax planning includes timely analysis and predetermination of cross-border transactions, careful planning of all international tax aspects of restructuring, s well as the right choice of entity form.  Form individual clients, prevalent questions include whether a green card holder should pursue U.S. citizenship, under what circumstances a U.S. citizen should abandon citizenship, preventing “exit tax” when leaving the United States, and avoiding double taxation.  Both corporate and individual clients must understand the impact of double taxation treaties and totalization agreements.

  • Advice on choice of entity
  • Interpreting double taxation treaties and totalization agreements
  • Advising on the tax aspects of life-changing events for individuals

Transfer Pricing

Transfer pricing becomes relevant whenever a multinational enterprise has to determine the pricing policies for cross-border transactions between affiliated entities. It is important to satisfy the rules of all countries where affiliated entities have to pay taxes, because governments all over the world are concerned about the artificial shifting of profits from a high-tax jurisdiction to a low-tax jurisdiction. Companies should plan in advance, maintain adequate documentation, and carefully consider their transfer pricing policies with detailed functions, risk and asset analysis whenever a restructuring is planned

  • Transfer pricing planning
  • Transfer pricing documentation
  • Advice on restructuring projects and transfer of functions
  • Advance Pricing Agreements (APA)
  • Mutual Agreement Procedures (MAP)

Tax Compliance

Tax compliance means to do what the tax authorities want you to do.  In the United States, this includes not only reporting income worldwide, but also filing “information returns” to notify the IRS about a variety of cross-border transactions and foreign assets regardless of whether they are taxable or not.  If the IRS catches omissions before you come forth, those omissions can become extremely expensive, so it is important to know about the amnesty programs that are available.

  • Meeting documentation requirements for foreign assets
  • Documentation of transactions with foreign entities
  • Delinquent returns and Reports of Foreign Bank and Financial Accounts (FBARs)
  • Streamlined procedure
  • Relief procedure
  • Other, less formalized approaches of damage control

U.S. Tax Return Preparation

Simple individual or even simple corporate returns are best handled by a competent local CPA or even with self-help software. When things get more complex, however, especially if international issues are involved, it can quickly become too complicated for the taxpayer or for a professional who does not specialize in international issues. The consequences can be costly.

  • Thorough review of pertinent information
  • Swift handling of federal and state tax returns, individual and corporate
  • Special attention to international issues

Communication with the IRS & Attorneys

Most taxpayers are uncomfortable dealing directly with the IRS. Many tax professionals in the United States, on the other hand, find it cumbersome to communicate with German-speaking colleagues whose English is not very good, or to decipher German-language documents, including tax returns. Another perceived obstacle is the location of your tax professional. These problems go away if you work with Hirsch Tax Law.

Typical situations include:

  • U.S. companies expanding their business from the United States to Germany or another country, or European companies exploring the market in the United States
  • Multinational enterprises planning to improve synergies and reduce their tax burden, or reducing risks, by transferring functions, risks and/or assets among affiliates, or by creating or closing affiliate entities
  • Executives of foreign companies who are working at a U.S. sister company, or vice versa
  • Individuals who are planning to move from the U.S. to another country, or vice versa
  • “Accidental Americans”: Those who were born in the U.S. but moved to another country as infants, or whose citizenship is based on a U.S. parent but who have lived all of their lives outside the U.S.
  • Those who live abroad and have been contacted by their bank about their U.S. citizenship​

Managing all communications and negotiations with U.S. tax authorities

Coordinating with German, Austrian, Swiss, or other attorneys outside the United States in their dealings with authorities in those countries.

Being available online at any time, no matter where you are or we are at the time

© 2021 Law Offices of Georg F. Hirsch PLLC