We can assist you with strategies to repatriate earnings from the U.S. in a tax efficient manner. This often involves the analysis of treaty issues in connection with minimizing U.S. withholding taxes as well as minimizing foreign tax costs that could arise.
Just like in the outbound context, repatriation planning from the U.S. often involves understanding a company's tax attributes such as earnings and profits ("E&P"), and tax basis. We can assist you with analyzing the status of your tax attributes through E&P and basis studies for your U.S. operations.