I am tax attorney specializing in U.S. income tax issues in the international context.  Many U.S. income tax issues can arise in situations, including the following:

- domestic corporations with activities abroad,

- foreign corporations with activities in the U.S., and/or

- domestic and foreign related corporations engaging in transactions together.

The IRS is increasing its enforcement of the international area, including the hiring and/or retraining of 900 agents to enforce this area.  Without proper planning, the results can be ruinous.  With the proper planning, U.S. income tax consequences can be minimized or legally avoided.