What We Do
The Firm of Allen J. Littman focuses primarily on international tax matters involving M&A, planning, compliance, and tax controversy. The firm is also experienced in legislative matters. Please see the examples below, which are only for illustration.
International tax planning:
- Cross-border M&A.
- Inbound planning for non-U.S. persons and businesses seeking to do business or invest in the United States, including restructurings, purchases and sales of U.S. real estate.
- Outbound planning for U.S. persons and businesses seeking to do business, invest, or restructure operations or investments in foreign countries.
- Inbound planning for U.S. immigrants and non-U.S. persons temporarily moving to the United States.
- Permanent or temporary expatriation of U.S. citizens or green-card holders.
- Withholding tax issues.
- Effective use of, and compliance with, tax treaties.
- IC-DISC export tax incentives.
- Transfer pricing matters.
- Tax implications of foreign currency transactions, including debt denominated in a foreign currency.
- Consulting on FATCA (Foreign Account Tax Compliance Act) for financial institutions, non-financial companies and individuals.
- Tax due diligence, issue identification and resolution.
Tax controversy and regulatory matters:
- Tax audits and appeals.
- Refund claims.
- Competent authority proceedings (to enforce your rights under tax treaties).
- Voluntary disclosure matters, including the “streamlined” program.
- IRS private letter rulings and advance pricing agreements.
- Comments on proposed regulations.
- Advice on status and prospects of proposed legislation.
- Development of proposed legislation.
- Planning legislative strategy.
Please note that the firm does not prepare tax returns.
What Sets Us Apart
- Cutting-edge experience from different perspectives of international taxation: tax advisor and implementer, Congressional Legislation Counsel, and corporate tax executive.
- Broad knowledge of international tax plus in-depth experience in numerous sub-areas.
- Extensive experience in global cross-border tax planning as well as tax controversy.
- Large firm skills and experience — but personalized client service. The firm and Allen care about your matter.
- Rates are competitive with the market for such tax services in North East Ohio (which has a relatively low cost of living for the United States).