Luis Dena Osollo

Questions relating taxation with respect to business planning (and personal estate planning) are particularly complex when more than one country is involved. Simple contexts in which such questions arise are when: (1) a citizen or resident of country A owns assets in country B; (2) a citizen of country A works (and lives) in country B; (3) a citizen of country A is married to a citizen of B; (4) citizen of country A lives in country B, owns assets in country C, dies while in country D, and so forth. The U.S. has a broad jurisdictional base for business and estate and gift taxation, taxing citizens regardless of their domicile or the location of their assets. Incidents of double (and triple) taxation are increasingly common (without proper planning). This is why it is critically important to consult with a qualified local legal professional to resolve the many complex issues in this area if you are considering expanding your business (and it's personnel) beyond the borders of the US, or are interested in establishing a foreign branch, subsidiary, or permanent establishment within the borders of the US from abroad. If you and your business are considering such an expansion, let me assist you so that we can discuss what inernational business and tax planning options are available given your specific plans and the target national markets that you wish to enter.

• Int'l Bus. & Tax Planning of Foreign Bus. Ops. in the US

California

State Bar of California

Solicitor of the Senior Courts of England and Wales

United States Court of International Trade (New York)

United States District Court, Northern District of California

United States Tax Court (District of Columbia)

California St Univ

B.A. | English

Santa Clara University School of Law

Law Degree

Honors: Law Faculty Research Assistant to Philip J. Jiménez, Professor of Law

Golden Gate University School of Law

LL.M. | Taxation (International Tax Planning Issues & Controversies Respecting Foreign Source Income of US Citizens, Resident Aliens, & US Bus. Operations Abroad; Estate Planning & Tax'n; Int'l Estate Planning for US Taxpayers, Pre- US Immigration Tax Planning)

The Hague Academy of International Law

Private International Law (Certificate)

2517 KJ The Hague, Peace Palace, The Netherlands

Honors: Charles A. Dana Foundation Scholarship Recipient

California State Bar

Member

Current

Law Society of England & Wales, London, United Kingdom

SRA-Regulated Solicitor

Current

United States Court of International Trade

Member of the Bar of the United States Court of International Trade

Current

"California's 'Unitary Method' of Allocating Jurisdiction to Tax Income from Multi-State (or Nation) Business: International Application and Implications"

6 Tilburg L. Rev. 289-367, Tilburg University, The Netherlands

January 1, 1997