THEVOZ Attorneys is a transatlantic tax law firm with offices in Geneva, Lausanne, New York and Austin providing tax services to companies and individuals with business interests in Europe and the United States. We work with clients to provide a tax structure that is compliant, consistent and rational, so that they can maximize opportunities in a global business environment.
As international tax attorneys who understand the concept of opportunity cost, or the strategic necessity to have a presence in a range of profitable markets and investing environments, THEVOZ Attorneys support our clients’ expansive business needs.
Compliance is always a major issue with businesses that operate across borders. No company wants to be the subject of a tax audit and be faced with penalties and fines that add up quickly. And THEVOZ Attorneys certainly has many years’ experience keeping its clients compliant with the tax laws of the US and Europe. But compliance is only the beginning of what our international tax practice can do for clients.
Starting a new venture in another country. If you have investigated an opportunity that requires setting up an entity in another country, THEVOZ tax planning and compliance law firm will help you set up the new entity in a way that minimizes tax liability going forward. We will help you answer the critical questions:
Compliance with myriad tax rules in Europe and the United States requires familiarity with a wide range of topics and jurisdictions. THEVOZ Attorneys’ presence on both sides of the Atlantic and the range of clients with whom we work keep us up-to-date with tax compliance issues in the United States and Europe. These include:
Tax treaties. Countries will sign a tax treaty to avoid double taxation and to develop an information sharing framework. Countries in the European Union, as well as other non-EU countries, have tax treaties with the United States. Of course, many non-EU European countries have tax treaties with other European countries, too. Once signed, a treaty is not set in stone; there are constant rule changes that can impact companies’ tax liability. THEVOZ Attorneys stay current on all tax treaties relevant to our clients and keeps them informed when rule changes impact tax liability.
Audits, negotiation and litigation. THEVOZ Attorneys represents clients in front of the governmental tax authorities. THEVOZ Attorneys gets involved in the dispute resolution process from the initial notice of audit all the way through any litigation. We stand by our work product and seek to protect our clients from any adversarial process with tax authorities.
Transfer pricing services within a group. The tax implications of transfer pricing with a group of companies are complex. All pricing must be “arm’s length,” which means the price agreed to by both ends of the transaction must reflect a realistic price in the market. Tax authorities are sensitive to the possibility that a group may move profits to a lower-tax country to limit tax liability, sometimes by using inflated transfer prices for key goods. We work closely with our clients' accounting departments to determine a supportable price that reflects all economic conditions, including patent protections. We also monitor any proposed rule changes to relevant tax treaties that could impact the transfer price scheme and that could result in fines and penalties, or benefits, for the client companies involved.
Due diligence, mergers and acquisitions. When buying or selling a company in a global business environment, it is a good idea to have someone who understands international tax law on your team. The tax implications of an acquisition or merger can be fundamental to profitability and, therefore, directly affects the offer price. THEVOZ Attorneys can be a key team member helping buyers or sellers work out the best deal because of our extensive background in financial accounting and tax best practices.
Estate, inheritance and gift taxes. The 2017 Tax cut and Jobs Act doubled the lifetime exemption for estate and gift taxes. The catch is that the current limits could expire in 2025 and revert to the old, lower limit. Careful tax planning is recommended to avoid beneficiaries being hit with a large tax bill after that date.
Moving a business to another country, or moving an employee to an assignment in another country. Some of the issues for moving a business, and the business’s principal, to another country include setting up a trust, paying the exit tax and how pensions should be handled. For an employee on temporary assignment to another country, issues can include tax withholding, social insurance contribution and pensions.
Tax treatment of life insurance. The tax effects of life insurance vary from country to country, and THEVOZ can review your life insurance tax liability in the relevant country.
Careful planning and a thorough knowledge of tax laws in the United States and Europe provide immeasurable benefits to THEVOZ clients as global opportunities expand. We provide advice and counsel that will help your company thrive, not just remain compliant. THEVOZ is well-known in Switzerland for providing excellent international tax planning services to companies from around the world. In fact, when a Swiss company is considering creating a business entity in the US and asks governmental authorities which law firms will best represent their interests, THEVOZ Attorneys is on the recommendation list. This is due to deep experience and knowledge of the relevant issues related to Swiss and international tax law.
Call us today at 512-523-5231 to see how we can help you globalize your business operations.
Federal Supreme Court – Case no. 2C_269/2013, 5 July 2013 Summary Facts On September 26, 2011, the Internal Revenue Service (IRS) filed a request for administrative assistance with the Swiss Federal Tax Administration (FTA). On April 5, 2012, the Federal Administrative Court granted an appeal that had been brought against the decision by the FTA,Read More
Federal Supreme Court – Case no. 4A_83/2016, 22 September 2016 Summary Facts The Swiss Bank A. participated in the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the Program) that was agreed upon between Switzerland and the United States in 2013. The Program was designed to regulate disputes between Swiss banks and theRead More