International Tax

We have extensive experience in advising small to middle-market companies operating abroad or foreign entities investing in the U.S. Our goal is to help your business succeed with its global business plan. Through our membership with Primerus, we have access to nearly 200 member firms in more than 40 countries to assist with your international operations.

Whether in the beginning stages of international expansion considering opening representative offices abroad, more developed companies that manufacture and distribute or provide services outside the U.S., or foreign entities investing into the U.S., we assist with choice of an entity or a branch; acquisitions; joint ventures; financings; foreign-loss utilization, holding companies, IP planning and cost-sharing. Our approach to tax planning is driven by your business operations, not vice versa.

International tax areas we can assist with include:

1.  Tax compliance (including Forms 1120F, 5471 and 5472)
2. Quantitative analysis including:
   • Foreign tax credit calculations including income sourcing, expense apportionment, interest allocation, determining creditable foreign taxes and Sec. 78 gross-up;
   • Dual consolidated loss determinations, calculations, elections and triggering-event exceptions;
   • Foreign exchange planning and calculations;
   • Elections and notifications;
   • Earnings &Profits and tax pool calculations;
   • Earnings stripping planning, structuring and calculations;
   • U.S. withholding tax determinations, remittance and compliance; and
   • Passive Foreign Investment Company (PFIC) calculations and filings.
3. Tax consulting and planning:
   • IC-DISC;
   • International tax planning projections and calculations;
   • Acquisition structuring and restructurings;
   • Disposition planning;
   • Cash repatriation;
   • Subpart F minimization;
   • Efficient use of foreign tax credits;
   • Financings and re-financings;
   • U.S. and foreign incentives; and
   • Tax treaty planning and interpretation including permanent establishment planning and determinations, limitation on benefits determinations and reducing or eliminating withholding taxes.

Transfer Pricing

Through our personal relationships with independent firms, we can coordinate planning and compliance to comply with the rules and regulations across numerous jurisdictions including but not limited to:

1. Base Erosion and Profit Shifting (BEPS);
2. Contemporaneous documentation and penalty protection;
3. Economic value chain / functional analysis;
4. Benchmarking analysis;
5. Internal Revenue Service and foreign audit support and defense; and
6. Planning including IP transfers, risk allocation, business operations re-structuring, among others.