
Contacts
- 716.848.1477
- 716.848.1212
Hodgson Russ tax attorneys provide guidance on the full range of U.S. business and personal tax issues for clients around the world, including multinational companies, public companies, privately held businesses, emerging technology companies, venture capitalists, investors, business owners, executives, and high-net-worth taxpayers.
Our mission is to provide creative solutions to allow our international clients to achieve their objectives in an ever-changing economic environment. We identify tax issues and find responses that take into account all relevant business, personal, and family considerations.
International Business Planning
We have decades of experience advising international business clients on a wide range of U.S. tax issues. Hodgson Russ’s Toronto office provides a base for our U.S. legal services to Canadian clients, and our South Florida, New York, and Buffalo offices also are heavily involved with multinational clients who require U.S. tax advice. We develop creative approaches to minimizing costs, reducing risks, and maximizing the tax benefits for cross-border clients, with the goal of providing seamless service to multi-jurisdictional clients. Our attorneys are routinely involved in:
- Choice of entity and capitalization issues
- Business expansion issues
- Inbound and outbound tax issues
- Mergers, acquisitions, and divestitures
- Hybrid structures and debt instruments
- Tax-effective joint venture arrangements
- Business restructuring
- Executive and employee transfer issues
- Treaty planning and interpretation
- Repatriation strategies
- International technology licenses, patents, and royalties
- Corporate anti-deferral issues for U.S. shareholders of foreign corporations, including CFC and PFIC matters
- Employment tax
- Withholding tax
- Dividend and loan taxation
- Tax matters related to joint ventures, partnerships, and limited liability companies
- Corporate tax matters of all kinds
- Real property
We also have extensive experience advising on tax planning for nonprofit and charitable organizations, including forming U.S. “friends” groups for cross-border fundraising.
Tax Planning for High-Net-Worth Individuals
Hodgson Russ attorneys frequently advise people with cross-border interests, including business owners, senior executives of public and private companies, entrepreneurs, venture capitalists, and high-net-worth individuals, on U.S. tax issues related to business and investment holdings.
Our counsel includes:
- Personal income tax planning
- Charitable gift planning
- Estate planning, including business succession planning
- Tax issues related to international business holdings
- Compensation issues, including stock options and other equity-based compensation, phantom stock, deferred compensation, rabbi trusts, golden parachutes, and retirement plan issues
- Expatriate planning, including tax issues related to immigration and visa matters
Tax Controversies
Hodgson Russ attorneys represent clients throughout the world in U.S. tax controversies from the auditor’s examination level through the appellate process and in the court system. We have successfully handled a wide variety of controversy work, including:
- Business taxation issues
- Personal income tax litigation
- Estate and gift tax controversies
- Cross-border matters, including transfer pricing disputes
- Acquisition of European Chemical Manufacturing Plant Requires Tax Planning, Debt Financing & Environmental Services
- Assisting Canadian Startup Expansion Into the United States
- Cross-Border Limited Partnership Structuring for U.S. & Canadian Citizen-Owned Business
- Ensuring U.S. Tax Compliance for Multinational Equity Plan
- Federal and State Tax Considerations for Nonresidents Owning U.S. Real Property
- IRS Voluntary Disclosure Assistance for Canadian Client
- Represented European-Owned Client in Major U.S. Acquisition
- Special U.S. Tax Counsel in Connection With the Redomestication of a U.S. Company
- Special U.S. Tax Counsel to U.S. Shareholders of Swiss Pharamceutical Company
- Tax and Estate Planning Advice to Trustees and Advisors of Foreign-Based Family Trusts
- Tax Planning for the U.S. Operations and U.S. Acquisitions of a Large Austrian Company
- Tax Related Matters - European Union Consulate
- U.S. Income and Estate Tax Planning Advice to Canadian Clients With Respect to U.S. Real Estate Investments
- U.S. State Tax and IPO Planning for Large, Privately Held Canadian Company
- U.S. Tax & Corporate Counsel for Multinational Joint Venture Group of Entrepreneurial Companies With Ties to Hong Kong, Canada, and the United States
- U.S. Tax Advice to Canadian Clients with Respect to Cross-Border Hybrid Structures
- U.S. Tax and Corporate Counsel to Business With Barbados-Domiciled Owner
- U.S. Tax Counsel for Reverse Takeover Transaction Involving Canadian Private and Public Companies
- U.S. Tax Counsel to Large, Private, Canada-Based Real Estate Company
- U.S. Tax Counsel to Large, Publicly Traded Canadian Company
- U.S. Tax Counsel to U.S. Company With Respect to Redomestication to Canada for Security Law Reasons
- U.S. Tax Planning for U.S.-Citizen Owners of Canadian Enterprise
In the News
- The Globe and Mail, October 24, 2023
- October 26, 2020
- The Globe and Mail, November 20, 2015
- Advisor.ca, June 22, 2015
- WBFO, April 14, 2014
- Canadian Manufacturing, December 23, 2013
- Law360, September 11, 2013
- September 9, 2013
- Buffalo Law Journal, , February 21, 2013
Press Releases
- November 30, 2022
- Press Release, March 20, 2014
Publications
- Hodgson Russ Federal-International Tax Alert, March 18, 2021
- Hodgson Russ Federal-International Tax Alert, November 19, 2020
- Hodgson Russ Federal-International Tax Alert, November 19, 2020
- Hodgson Russ International Tax Alert, April 22, 2020
- Hodgson Russ Federal-International Tax Alert , March 27, 2020
- Hodgson Russ Federal-International Tax Alert , March 26, 2020
- Hodgson Russ Federal-International Tax Alert, March 19, 2020
- Canadian Tax Highlights, October 16, 2019
- Canadian Tax Highlights, October 16, 2019
- Hodgson Russ Federal and International Tax Alert, September 9, 2019
- Canadian Tax Highlights, June 24, 2019
- Canadian Tax Highlights, May 15, 2019
- Canadian Tax Highlights, April 15, 2019
- Canadian Tax Highlights, April 15, 2019
- Canadian Tax Highlights, January 22, 2019
- Canadian Tax Highlights, November 15, 2018
- Canadian Tax Highlights, October 25, 2018
- Canadian Tax Highlights, September 27, 2018
- Business Tax & International Tax Alert, July 30, 2018
- CleanTechIQ, July 9, 2018
- Canadian Tax Highlights, July 2018
- Canadian Tax Highlights, March 1, 2018
- Canadian Tax Highlights, March 1, 2018
- Federal and International Tax Alert, December 18, 2017
- Tax Alert, November 13, 2017
- Tax Alert, November 6, 2017
- Business Tax & International Tax Alert, March 15, 2017
- Canadian Tax Highlights, November 11, 2016
- Canadian Tax Highlights, October 2016
- Canadian Tax Highlights, September 2016
- Canadian Tax Highlights, August 2016
- Canadian Tax Highlights, May 2016
- STEP Connection, Toronto Branch Newsletter, April 2016
- Canadian Tax Highlights, October 2015
- Canadian Tax Highlights, September 2015
- International Tax Alert, September 11, 2015
- Canadian Tax Highlights, August 2015
- Canadian Tax Highlights, July 2015
- Canadian Tax Highlights, June 2015
- Canadian Tax Highlights, April 2015
- Canada-U.S. Cross-Border Alert, February 25, 2015
- Buffalo Law Journal, January 8, 2015
- Canada-U.S. Tax Traps and MismatchesSTEP Inside, October 2014
- Lawyers Weekly, October 17, 2014
- Hodgson Russ Publication, June 2014
- Hodgson Russ Alert, February 7, 2014
- Lawyers Weekly, November 29, 2013
- Federal/International Tax Alert, September 5, 2012
- Federal/International Tax Alert, March 6, 2012
- Federal/International Tax Alert, January 12, 2012
- Federal/International Tax Alert, December 13, 2011
- Federal/International Tax Alert, February 9, 2011
- Federal/International Tax Alert, March 18, 2010
- Federal/International Tax Alert, March 4, 2010
- Buffalo Law Journal, May 7, 2009
- The Bottom Line, May 2009
- Canadian Tax Highlights, September 1, 2007
- December 15, 2006
- Buffalo Law Journal, July 14, 2005
- Buffalo Law Journal, March 24, 2005
Presentations & Events
- Seasons 52, November 2, 2023
- Holiday Inn Binghamton Downtown, 2-8 Hawley Street, Binghamton NY 13901, October 26, 2023
- Ontario Bar Association, May 4, 2023
- ABA Section of Taxation 2022 Fall Tax MeetingDallas, TX, October 13, 2022
- November 17, 2021
- October 7, 2021
- June 29, 2021
- May 19, 2021
- April 28, 2021
- November 17, December 1 & 15, January 5 & 19
- Toronto, Ontario Canada, January 30, 2020
- Buffalo, NY, November 7, 2019
- Las Vegas, Nevada, June 11, 2019
- Webinar: U.S. Corporate Entity Options and the Corresponding Tax Implications for European CompaniesJanuary 24, 2019
- Toronto, ON, October 22, 2018
- Markham, Ontario, September 26, 2018
- Coming to Terms with US Tax ReformUS Tax Reform Seminar & Live WebcastFairmont Royal York Hotel, April 5, 2018
- October 20, 2017
- Toronto, ON, June 18, 2015
- Toronto, ON, June 18, 2015