Foreign Investment in the U.S.

Overview

"Every individual I have met at Blank Rome is impressive. They are strong in all areas. They are my first choice as counsel and will remain so.”

— Client feedback, Chambers USA

Unlike the tax structure of many countries (which often have only one level of tax), nearly every level of government in the United States imposes some type of tax on non-U.S. companies. The method of taxation can take many different forms and can be measured in a number of ways. The jurisdiction could, for example, impose tax upon income earned in the jurisdiction, the value of property located within the jurisdiction, or the consideration paid for property or services transferred within the jurisdiction. 

U.S. businesses dedicate substantial resources planning for and complying with the various tax schemes established by local governments. Your investments in the United States—whether by acquisition or organic growth—should be treated no differently. 

Blank Rome’s attorneys can help you navigate the layers of U.S. tax law and the impact of foreign treaties on a federal, state, and local level within the United States.

How We Can Help

  • corporations, partnerships, limited liability companies, and joint venture arrangements (including exempt organizations/for-profits)
  • taxable and tax-free reorganizations, liquidations, mergers, and acquisitions
  • U.S. federal, state, and local civil and criminal tax controversies, including audits, administrative appeals, and litigation
  • executive compensation arrangements, including stock options and other stock-based plans
  • taxation of banks, financial institutions, financial instruments, real estate transactions (including REITs, new market tax credits, real estate funds and joint ventures), private investment funds, mutual funds, trust and estates, tax-exempt and philanthropic organizations
  • IRS tax controversy involving tax-exempt organizations
  • strategic state and local tax-saving opportunities
  • debt workouts
  • tax shelters, estate planning, and charitable giving
  • tax consequences regarding matrimonial matters
  • tax issues related to maritime matters
  • international tax matters, including inbound, outbound and passive investments, transfer pricing, tax residency, and establishing foreign entities
  • preparation of legal opinions and requests for letter rulings from the Internal Revenue Service and other government authorities

What Sets Us Apart 

  • 2017 Chambers USA: ranked Blank Rome for Tax in Pennsylvania.
  • Members of Blank Rome’s tax group have previously served as CPAs and members of “Big Four” national tax practices. 
  • Our attorneys also serve as adjunct professors in law schools and graduate tax programs.
  • We’re composed of former government officials from the IRS, Department of Justice and the Treasury who have strategic relationships within Congress and who have presented before the Senate Finance and House Ways and Means Committees.
  • We frequently represent clients in rule-making proceedings and shape and advance tax policy objectives before the U.S. Treasury Department, including the Internal Revenue Service.