Tax Planning in Internationalization: Legal and Fiscal Strategies to Avoid Double Taxation between Brazil and the United States

This article examines advanced legal and fiscal strategies to mitigate the effects of double taxation between Brazil and the United States, in the absence of a bilateral tax treaty. Drawing on theoretical frameworks, legislative analysis, and practical professional experience, it explores optimal corporate structures, the use of international holding companies, profit distribution planning, contractual arrangements to reduce withholding taxes, and integrated compliance mechanisms. Real-world case studies illustrate both successful and failed approaches, highlighting the importance of preventive planning, coordinated legal–accounting governance, and strategic risk management. The paper aims to provide entrepreneurs, lawyers, and accountants with actionable guidance for achieving tax efficiency, legal security, and long-term sustainability in cross-border operations.