James Nobles LLC has, for several years, provided specialized advice to foreign clients investing in the U.S.  Over the course of representing many clients from all regions of the world as they invest in the U.S., we have acquired a great deal of expertise in this area.

     Over the past few years, the U.S. regulatory environment for inbound investment has dramatically changed.  Congress has come to view foreign investors as a fertile source of tax revenues which triggers no adverse reaction at the voting polls.  At the same time that Congress has enacted very burdensome laws aimed at increasing the tax revenues foreign investors pay in the U.S., the U.S. Internal Revenue Service has put foreign investors under increased scrutiny to ensure that they pay their fair share of taxes.  Today, efficient tax structuring is a critical centerpiece of all successful foreign investment into the U.S.  Utilizing our years of experience, we design our clients' inbound investments to be efficient in the context of their global tax situations, taking into account their home country tax burden as well as the impact of any applicable tax treaties.

     James Nobles LLC has represented investors from many regions of the world in investing in a wide variety of U.S. investments, including real estate (apartment complexes, shopping centers and timberland as well as raw land), and numerous, diverse industries such as the handling equipment industry, computer and software industry, the printing industry and the hotel industry.

• Inbound Investment Structuring     A core service which James Nobles LLC provides to clients is the structuring of their inbound investments.  We work with our clients' foreign and domestic financial officers, advisors and accountants to reduce the total tax burden of the investment as well as to plan the eventual repatriation of the investment and earnings upon disposition.  For some clients, James Nobles LLC also monitors client's investments structures on an ongoing basis to make adjustment for changes in the tax and regulatory environment.
  
  

• Intercompany Pricing Agreements     Due to the intense scrutiny tax authorities now place on intercompany transactions, it is imperative that all intercompany relationships be documented through intercompany pricing agreements.  James Nobles LLC advises clients on structuring intercompany relationships and prepares intercompany agreements to comply with U.S. and foreign intercompany arm's length pricing standards.
  
  

• Inbound Joint Ventures     A popular way for foreign companies to enter the U.S. market is through joint ventures and other strategic relationships.  James Nobles LLC has represented several foreign companies to structure joint ventures with American companies which have facilitated our clients' entry into the U.S. marketplace.
  
  

• Acquisition of U.S. Companies     In the acquisition of U.S. companies, foreign investors must be concerned with unique financing, ownership, governmental clearance and reporting requirements.  James Nobles LLC has advised foreign clients in stock transactions as well as asset purchases of U.S. companies, including those structured as management buyouts and acquisitions of minority interests.
  
  

• Investment in U.S. Real Estate     James Nobles LLC has represented numerous clients making investments in U.S. real estate to advise them on the investment structure as well as tax planning under the Foreign Investment in Real Property Tax Act (FIRPTA).
  
  

• Start-Up Operations     Many of our clients are foreign companies entering the U.S. market for the first time.  These clients need specialized attention to acclimate them to the U.S. legal environment as well as to ensure that they meet the legal requirements to commence their U.S. operations.
  
  

• Licensing of Foreign-Based Technology     A component of a U.S. market entry program for many foreign companies is the licensing of their technology to a U.S. company, either as a part of an investment or as a stand alone license agreement.  Over the years, we have advised many foreign clients on their inbound licensing transactions and prepared the license agreements to document the transactions.
  
  

• Foreign Lenders Financing U.S. Operations     Many U.S. companies, including those having U.S. ownership, obtain loan financing from foreign financial institutions and other lenders.  Foreign lenders face high U.S. withholding taxes unless one of the narrow exceptions applies.  For these lenders, we advise them on structuring the loans to come within the withholding exceptions (when possible).
  
  

• Representation & Distribution Agreements     Foreign companies entering into representation and distribution agreements with U.S. companies need specialized advice in preparing the agreements, particularly since the foreign companies typically are familiar with a legal and business culture which is very different from that of the U.S.  James Nobles LLC has advised foreign clients on U.S. representation and distribution arrangements for many diverse industries.
  
  

• International Trade Disputes and Litigation     James Nobles LLC has advised clients on international trade disputes, and, working with litigation counsel, has represented clients in litigation over trade-related matters, including issues such as non-performance of a trade agreement, non-delivery, and other breach issues.