When the Structure’s Off, So Is the Outcome
Business transactions are rarely simple. Whether you’re acquiring a company, forming a U.S. subsidiary, or expanding across borders, every step comes with legal and tax implications that can affect your exposure, profitability, and long-term goals.
Missed filing obligations. Misclassified income. Poorly structured deals. These aren’t just footnotes—they’re risks that can lead to audits, penalties, and costly do-overs.
With so much riding on each decision, the right transactional law strategy isn’t a luxury—it’s a necessity.
Guidance for Growth, Expansion, and Investment
Our clients come to us when the stakes are high, the structure matters, and every move needs to align with broader business goals.
Foreign Businesses
Entering the U.S.
We help international companies establish U.S. operations, navigate treaty and tax implications, and avoid triggering permanent establishment or unexpected filing obligations.
U.S. Companies
Expanding Abroad
When domestic businesses grow globally, our transactional attorneys provide tax-efficient structures, help manage GILTI and Subpart F exposure, and ensure compliance with international reporting requirements.
Established Businesses & Investors
For those acquiring, merging, or restructuring entities, we offer the legal and tax clarity needed to minimize risk and ensure smooth execution—whether the deal is domestic or cross-border.
Advisors & Legal Teams
We partner with CPAs, general counsel, and business transaction attorneys who need precise, well-rounded guidance on the tax consequences of their clients’ business moves.
Transactional Counsel for Domestic and International Transactions
Lincoln PLLC helps businesses structure transactions that protect long-term value and reduce compliance risk.
Foreign Companies Expanding into the U.S.
We assist international clients in assessing U.S. tax exposure, minimizing risk, and establishing compliant operations.
- U.S. entity selection and formation
- U.S. Trade or Business and Effectively Connected Income (ECI) analysis
- FDAP classification and 30% withholding under §§1441–1446
- FIRPTA withholding on U.S. real estate interests
- Permanent establishment and treaty-based planning
U.S. Companies Investing Abroad
From international structuring to earnings repatriation, we help U.S. businesses reduce global tax burdens.
- Subpart F and GILTI mitigation strategies
- High-tax exception (HTE) and QBAI optimization
- Foreign tax credit planning and §861 allocation
- Treaty re-sourcing rules and dual-residency risks
- Section 245A deductions and §956 avoidance for repatriation
Domestic Acquisitions and Dispositions
We support clients on complex domestic transactions where business goals and tax exposure are closely linked.
- Stock and asset purchase structuring
- Section 338(h)(10) and 336(e) transactions
- Internal reorganizations and integration planning
- Transactional tax due diligence and deal review
PFIC & Investment Structuring
Avoid costly tax treatment and preserve long-term investment goals with proactive PFIC planning.
- PFIC identification and QEF / MTM elections
- Integration with estate and gift planning for multigenerational investors
Trusted for the Transactions That Matter
Our team of transactional lawyers balances legal insight with a real-world perspective, delivering the clarity and focus high-stakes decisions demand.
Put Experience on Your Side
Whether you’re expanding into new markets, acquiring a business, or evaluating tax exposure on a cross-border deal, connect with a business transaction attorney who understands what’s at stake.