Mark Williams' international tax practice encompasses all areas of international tax planning, with special emphasis on supply-chain transfer pricing solutions, global tax mitigation, and cross-border transactional strategies. In addition, Mr. Williams has substantial experience in the areas of international tax planning involving high net worth individuals (both U.S. and foreign nationals), as well as general corporate taxation, partnership taxation, and tax controversy matters.
Representative and Continuing Matters:
- Structuring the foreign operations of various Fortune 500 companies, with special emphasis on supply-chain transfer pricing solutions involving intellectual property, manufacturing, and distribution functions.
- Global tax mitigation planning for various Fortune 500 companies, with special emphasis on foreign tax mitigation, U.S. income tax deferral, and repatriation planning.
- Structuring and reorganizing the foreign legal and operational platforms of various closely held and mid-size public companies, with special emphasis on cross-border transactions involving intangibles, cost-sharing arrangements, commissionaire arrangements, and other forms of centralized/decentralized cross-border legal organizations and operations.
- Advising various U.S. and foreign concerns related to both outbound and inbound joint venture planning, with special emphasis on the international tax aspects associated with joint venture formation, continuing operations, and exit planning.
- Treaty-based holding company planning with respect to U.S. and foreign multinational companies, principally focusing on the tax-efficient movement of funds and minimizing exposure to double taxation.
- Tax-efficient entity and asset acquisition planning for various U.S. closely held and public multinational companies and post-transactional global tax mitigation restructuring planning.
- Tax-efficient entity and asset disposition planning for various foreign and U.S. multinational companies.
- Advising U.S. and foreign technology "start-up" companies relative to legal formation, continuing operations, and exit strategies, with special emphasis on intangible property development, incubation, geographical location and deployment.
- Foreign tax credit optimization planning for U.S. multinational companies with respect to both deferral and conduit structures, with special emphasis on integrating foreign partnership vehicles into deferral structures.
- Wealth preservation planning for various high net worth U.S. and foreign national families utilizing foreign/domestic foundations/trusts and foreign/U.S. holding company structures, with special emphasis on U.S. and foreign income tax and transfer tax mitigation strategies.
- Advising a significant number of high net worth U.S. citizens and residents relative to the suitability and appropriateness of entering the IRS Voluntary Disclosure Program.
- Representing numerous U.S. citizens and residents in the IRS Voluntary Disclosure Program and at the U.S. Department of Justice.