Structuring and analysis of a multinational services partnership in relation to ECI allocation and US withholding obligations under S. 1446 for non-US partners; advice on timing and procedural application for refund of over-withheld monies with respect to non-US partner.

Analysis of US-German income tax treaty, estate tax treaty and totalization agreement (Social Security tax treaty) for cross-citizenship couple with dual tax residency involving cross-border trusts, beneficiaries and generation-skipping transfer tax.

Analysis of implications of non-US investor taking position in the US on their non-US investment portfolio from a US tax perspective (PFIC analysis, MTM election, etc.)