International Tax Planning Lawyers

Serving the U.S., Latin America, the Caribbean, and Central America

Cross-border planning often takes more than technical tax knowledge. It calls for a partner who understands how treaties, domestic rules, and commercial objectives interact across jurisdictions. At Bridgepointe Global Counsel, our bilingual lawyers in Coral Gables work with businesses and high-net-worth families to translate complex international tax concepts into practical transactional outcomes. 

Founded in 2015 and with experience handling thousands of matters, we combine global perspective with a client-centered approach to help you navigate treaty provisions, repatriation strategy, and cross-border compliance in a way that respects both local realities and your long-term goals.

We treat each engagement as a strategic relationship, not a single deliverable. We’ll work with you towards an evolving plan that aligns tax planning with your estate, asset protection, and corporate compliance objectives. Whether you are structuring dividend flows, licensing IP across borders, or planning the tax-efficient repatriation of earnings, we strive to create cohesive plans that encompass all facets of your operations. 

You can schedule a free consultation by calling our office at (786) 882-4122.

Tax Treaty Interpretation for Transactional Confidence

One of the most consequential elements of post-transaction structures in the international system is whether the payments of dividends, interest, or royalties qualify for favorable treaty rates.

Limitation on Benefits (LOB) articles are the gatekeepers. They allocate treaty benefits to entities that meet specified ownership, activity, or substance tests and block benefits where treaty abuse is suspected. Misreading or overlooking LOB tests can produce unexpected withholding, administrative burdens, and retroactive tax exposure. 

Here are some of the practical steps you can count on when working with our experienced lawyers: 

• Pre-deal diagnostic. We map the flow of funds, identify payer and payee jurisdictions, and confirm whether the recipient is the “beneficial owner” under relevant treaty language.
• LOB analysis. We apply the treaty’s specific LOB tests, including ownership-based, base-erosion, derivative benefits, or active business tests, and determine whether existing shareholders or planned post-closing ownership satisfies those thresholds.
• Substance and documentation. We coordinate corporate governance, local presence, and intercompany agreements to align legal form with economic reality. Proper documentation is critical for administrative relief.
• Alternative structures. If LOB outcomes are unfavorable, we evaluate options, including intermediate holding companies in treaty-friendly jurisdictions, contractual re-characterizations, or exploiting domestic reliefs like the foreign tax credit, to reduce your net tax cost while remaining compliant.
• Rulings and compliance filings. For high-risk matters, we assist in seeking advance rulings or competent-authority relief and prepare the filings that aim to minimize audit friction in both payer and recipient countries.
• Integrated review. We coordinate treaty planning with transfer pricing, corporate compliance, and domestic tax planning so withholding positions do not create downstream exposures.

Our transactional planning is practical and risk-aware. We weigh the tax benefit of treaty reliance against operational complexity, reputational exposure, and enforcement trends in the region. In markets across Latin America, the Caribbean, and Central America, treaty language and domestic anti-abuse measures vary, so a one-size-fits-all approach is rarely effective.