Tax, International

Cross-Border Transactions and Structuring

• Structured cross-border mergers, acquisitions, and joint ventures involving U.S., Mexican, and other Latin American entities, including complex multi-jurisdictional reorganizations and investments.
• Negotiated a platform joint venture agreement with Morgan Stanley Real Estate Investment Funds for the development and investment in retail properties in China and India (approximately $300 million).
• Advised clients on structuring global operations, financing arrangements, and equity investments across multiple jurisdictions, including coordination of tax treaty benefits and repatriation strategies.

Inbound and Outbound Investment

• Advised foreign companies, financial institutions, and investors on establishing and structuring operations in the United States, including compliance with U.S. tax laws and reporting regimes such as FATCA.
• Counseled U.S. companies on outbound investments and business operations in Latin America and Asia-Pacific markets, including joint ventures, manufacturing, and distribution structures.
• Represented multinational companies in structuring cross-border financing, real estate investments, and private equity transactions across the Americas.

International Tax Planning for Individuals and Families

• Represented international entertainers, including Grammy Award-winning artists, in structuring global income, publishing, and touring activities, as well as related tax-exempt and investment structures.
• Advised multinational families and high-net-worth individuals on cross-border wealth structuring, including income, estate, and inheritance tax planning across jurisdictions.
• Counseled foreign individuals planning to relocate to the United States and U.S. individuals investing or relocating abroad on pre-immigration, expatriation, and global asset structuring.

Compliance, Reporting, and Risk Management

• Advised U.S. and foreign clients on compliance with international tax reporting requirements, including cross-border entity governance and reporting obligations for global operations and assets.
• Assisted multinational companies in developing compliance programs for U.S. tax obligations related to international operations.
• Advised clients on the impact of evolving U.S. tax laws and international regulatory developments on cross-border transactions and operations.

Cross-Border Disputes and Enforcement

• Represented clients in international tax audits and disputes involving treaty interpretation, residency, and cross-border reporting obligations.
• Enforced intellectual property and commercial rights for clients in cross-border contexts, including successful administrative and criminal enforcement actions in China involving counterfeit goods and online infringement.
• Coordinated multi-jurisdictional dispute and enforcement strategies across U.S. and foreign jurisdictions.

For more than two decades, Procopio has hosted the Procopio International Tax Institute (PITI), a premier forum focused on the latest developments in cross-border tax and international business. Now in its third decade, the conference brings together government officials, corporate leaders, and leading tax practitioners from across the United States and Latin America to address evolving legal, regulatory, and policy challenges.

PITI reflects the core of our international tax practice. Through ongoing dialogue with policymakers, advisors, and industry leaders, we stay closely aligned with emerging trends in international taxation, including cross-border structuring, compliance, enforcement, and regulatory reform. The conference provides a platform for practical insights and real-time perspectives on developments shaping global tax strategy, particularly in the U.S.–Mexico and broader Americas context.

This commitment to thought leadership and collaboration informs how we advise clients. By engaging directly with those shaping tax policy and global business, we are able to provide guidance that is both current and grounded in real-world developments.

When should a company involve international tax counsel in cross-border activities?

As early as possible. Tax considerations often affect how a transaction or expansion is structured, including entity selection, financing, and ownership. Early planning provides more flexibility and helps avoid inefficiencies or unintended consequences later.

What are the key tax considerations when entering the U.S. market?

Foreign companies should consider entity structure, tax exposure, reporting obligations, and how income will be treated under U.S. tax law and applicable treaties. Planning at the outset can help manage tax liability and simplify ongoing compliance.

How do you assist U.S. companies expanding into foreign markets?

We work with clients to structure outbound investments and operations in a tax-efficient manner, taking into account local tax regimes, treaty benefits, repatriation strategies, and coordination with foreign advisors. The goal is to align tax strategy with operational and business objectives.

What is the difference between inbound and outbound tax planning?

Inbound planning focuses on foreign entities and individuals investing in or doing business in the United States. Outbound planning addresses U.S.-based clients expanding abroad. Each raises different considerations, including tax exposure, reporting requirements, and applicable treaty frameworks.

How do tax treaties impact cross-border transactions?

Tax treaties can significantly affect how income is taxed across jurisdictions, including reducing withholding taxes and helping avoid double taxation. Proper interpretation and application of treaties is critical in structuring transactions and managing ongoing operations.

What should companies know about international tax compliance and reporting?

Cross-border operations often trigger complex reporting requirements under U.S. and foreign tax regimes. These can include disclosures related to foreign entities, accounts, and transactions. Establishing a clear compliance strategy helps reduce risk and avoid penalties.

How do international tax issues affect individuals and families?

Individuals with cross-border investments, residency changes, or multinational family structures may face overlapping tax obligations. Planning can help address income, estate, and gift tax considerations, particularly in connection with relocation, investment, or succession.

When should individuals consider pre-immigration or expatriation tax planning?

Before a move occurs. Tax consequences can vary significantly depending on timing and structure. Early planning allows individuals to organize assets and investments in a way that minimizes tax exposure and simplifies compliance.

What should a company do if it faces a cross-border tax audit or dispute?

It is important to respond early and strategically. We help clients assess the issue, coordinate with relevant authorities, and develop a plan for resolution, often in coordination with our Tax Controversy team and local counsel in other jurisdictions.

How do you manage multi-jurisdictional matters without offices everywhere?

We coordinate closely with trusted law firms in key jurisdictions, allowing us to provide integrated advice across borders. This approach ensures clients receive consistent, high-quality guidance while maintaining efficiency and flexibility.

How do you stay current with evolving international tax rules and policy changes?

International tax is constantly evolving, with changes driven by legislation, regulatory guidance, and global initiatives. Through active engagement with policymakers, industry leaders, and forums such as the Procopio International Tax Institute (PITI), we stay closely aligned with developments that impact our clients.

When should a company consider changing or expanding international tax counsel?

Companies often reassess counsel when expanding into new markets, undertaking cross-border transactions, or facing more complex compliance or dispute issues. This is particularly relevant when a more integrated, cross-border approach is needed.