International Tax Services

The International Tax Group at Marks Paneth provides a complete suite of services to meet your international tax needs, including tax planning, structuring, consulting, compliance and controversy. Whether you are a U.S.-based business looking to expand abroad, or a foreign company looking for exposure to U.S. markets of any type, our professionals can help you confidently navigate the global marketplace.

With the recent U.S. tax reform, updates by the OECD, and new economic trends across the globe, working with an experienced international tax consultant is more pivotal than ever to ensure your business is taking advantage of tax optimization structures and operating in global compliance. Our seasoned International Tax advisors, who have experience at the IRS Office of the Chief Counsel, national accounting firms and law firms, are dedicated to delivering customized and effective solutions.

Our commitment to providing high-quality international tax services is augmented by our membership in Morison KSI, a global association of 154 leading, independent accounting and consulting firms operating across 82 countries. 


  • Foreign tax credit calculations
  • Deduction limitations, allocations, and apportionment
  • Sourcing matters
  • Subpart F, Transition Tax, GILTI and FDII
  • Cross border acquisitions, structuring, and M&A
  • Corporate finance arrangements
  • Repatriations
  • Foreign currency
  • Permanent establishment and attributions
  • Treaty applications
  • US trade or business determinations and effectively connected income
  • Taxation of Real Estate Investments (FIRPTA)
  • Withholding under Chapter 3 and FDAP considerations
  • FATCA and Chapter 4
  • Broker/dealer, trader, banking, custodian, clearer and investor issues
  • Individual residency and expatriation issues
  • Check-the-Box and entity classification
  • Branch profits tax
  • Branch level Interest tax
  • Cross-border service providers
  • Import and Export
  • Compliance with information reporting
  • Controversy issues, including dual audits
  • Competent Authority Issues


Mark R. Baran
Paul Bercovici
Julio M. Jimenez