What it is
Tax Law at Melleh Law focuses on how individuals and businesses structure, operate, invest, and transfer wealth with clear, defensible tax outcomes—in the U.S. and across borders. We help clients plan transactions to minimize double taxation, align with treaties, and meet federal, state, and local requirements, coordinating closely with CPAs and foreign counsel where needed.

A coordinated, treaty-aware approach
There is no single “right” structure. We start with your goals, residency, asset profile, and the countries involved. Then we design a plan that integrates entity choice, sourcing rules, withholding, treaty relief, and reporting so decisions made today hold up under audit tomorrow. For international families and companies, we pay special attention to residency and domicile, asset situs, permanent establishment risk, and information reporting.

Who we serve

• Founders, executives, and investors (U.S. and non-U.S.) launching or expanding businesses

• Individuals moving to or from the United States (pre-immigration / expatriation planning)

• Family offices and closely held groups with multi-jurisdiction holdings

• U.S. residents with foreign assets, and non-residents with U.S. income or property

What we deliver

• Tax planning memoranda and written guidance (alternatives, benefits, and risks)

• Entity & deal structuring for operations, financing, and asset holding (U.S. and cross-border)

• Treaty analysis (tie-breaker, reduced rates, limitation-on-benefits) and withholding roadmaps

• Compliance mapping: who files what, where, and when (U.S. returns and information reports)

• Implementation with corporate documents, elections, and coordination among CPAs, banks, trustees, and foreign advisors

• Controversy support: responses to IRS/state notices, penalty-abatement strategies, exam readiness, and appeals coordination

Typical strategies we may employ

• Business tax planning: LLC vs. Corporation, check-the-box elections, holding/operating splits, blocker entities for investors, multi-state nexus and sales/use tax readiness

• Cross-border flows: international financing, royalties and licensing, service arrangements, transfer-pricing governance, and documentation of economic substance

• Pre-immigration / expatriation: timing, basis step-ups, sourcing, treaty positions, and U.S. reporting readiness

• Investment & real estate: FIRPTA considerations for non-U.S. sellers, debt/equity mix, and cash-repatriation paths

• Owner/employee planning: compensation, equity awards, and withholding/ reporting coordination

• Advisory & opinions: memos and formal consultations on interpretation and application of tax rules to specific facts

Brazil & other foreign jurisdictions
For inbound/outbound structures—such as foreign investments in Brazil or Brazilian investment into the U.S.—we provide U.S. tax strategy and coordinate with Brazilian tax counsel to align regimes, incentives, and reporting on both sides, reducing the risk of double taxation.

Our process

1. Fact map & objectives — residency, assets, revenue streams, jurisdictions, timelines

2. Modeling & options — side-by-side comparison of tax outcomes (cash, ETR, compliance)

3. Implementation — elections, documents, banking/onboarding, and withholding instructions

4. Compliance calendar — returns and information reports; roles and deadlines

5. Monitor & defend — periodic reviews; support on notices, exams, and evolving rules

This overview is for informational purposes only and does not constitute legal advice. Outcomes depend on your specific facts and the laws, regulations, and treaty provisions that apply to your matter.