Nicholas J. Heuer focuses his practice on international income and transfer tax matters. He regularly assists high-net-worth individuals and families that are based in countries throughout the world by providing solutions to complex tax issues that arise when their business activities or family members have ties to the United States.
In this regard, he works with foreign banks, trust companies, financial advisors, and foreign lawyers in order to create and execute international strategies for investment within the United States and abroad, as well as the preservation and transmission of wealth for cross-border families.
Nick routinely provides tax advice in, and assists with drafting documents related to, a wide variety of global transactional matters. His tax advice includes inbound and outbound analysis, tax treaty examination, and the design and implementation of tax-efficient international structures for multinational companies. He represents corporations, partnerships, trusts, and individuals—both foreign and domestic—concerning income tax matters that result from conducting business within and without the United States. He has broad experience advising on domestic and cross-border mergers, acquisitions, dispositions, joint ventures, spin-offs, tax-free reorganizations, and IC-DISCs.
To supplement Nick’s international private client and transactional practice, he provides counsel on the various tax reporting requirements that arise from activities having a connection with the United States. This includes tax compliance obligations for foreign individuals and companies with businesses and investments in the United States, as well as U.S. persons with offshore businesses and investments. In connection with this, Nick drafts tax compliance memoranda, evaluates FATCA and CRS classifications and obligations, assists with expatriation, and counsels non-compliant taxpayers through the various voluntary disclosure programs.