International Tax Attorney in Chicago
International tax planning is essential for businesses and individuals with cross-border activities. At Liberum Law, our international tax attorneys in Chicago advise on tax-efficient structuring of international operations, investments, and transactions.
Our international tax practice covers transfer pricing strategy and documentation, tax treaty planning and application, FIRPTA compliance for foreign investment in U.S. real property, withholding tax compliance on cross-border payments, permanent establishment analysis and risk management, international entity structuring for tax efficiency, FATCA and CRS reporting compliance, and tax considerations for inbound and outbound investment.
Contact our international tax attorneys at Liberum Law for a free consultation.
Frequently Asked Questions
What is the U.S. international tax framework?
Worldwide taxation of U.S. persons (citizens, residents, entities) on global income, with foreign tax credits to mitigate double taxation. Special rules for: controlled foreign corporations (CFCs/Subpart F), passive foreign investment companies (PFICs), expatriates, foreign accounts, and U.S.-source income of non-residents.
What is GILTI?
Global Intangible Low-Taxed Income — U.S. tax on excess foreign earnings of CFCs above a normal return on tangible assets. Effectively a minimum tax on offshore earnings. Mainly affects U.S. multinationals with significant foreign IP or low-tax operations.
Do I need to report my foreign bank account?
If you're a U.S. person (citizen or resident) with foreign accounts aggregating more than $10,000 at any time during the year, yes — file FBAR (FinCEN 114). If foreign financial assets exceed $50,000+ at year-end, also Form 8938 (FATCA). Penalties for non-filing are severe.
What is the foreign tax credit?
Mechanism allowing U.S. taxpayers to reduce U.S. tax by foreign taxes paid on foreign-source income. Subject to complex limitations and categorization rules. Available as a credit (preferred) or deduction. We coordinate with accountants on optimization.
What is expatriation tax?
Exit tax on certain wealthy individuals who renounce U.S. citizenship or terminate long-term residency — covered expatriates owe mark-to-market tax on worldwide assets. Triggered by net worth ≥$2M, average tax liability above threshold, or failure to certify tax compliance. Pre-expatriation planning is essential.
