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Overview

The globalization of capital markets and the multinational structure of business organizations have brought about the need for internationalization of accounting standards.  The economies of virtually every country in the world have become increasingly interdependent due to international business developments, and the urgency in harmonizing accounting standards is imperative.  The flow of accounting reports across national borders produces the need for an international uniformity in accounting. We have in-depth knowledge of the international accounting standards and specialize in assisting clients who conduct businesses in multiple countries.

In the ever-changing global tax jurisdictions, we can furnish your company with professional services designed to maximize your company’s overall growth potential in the international marketplace, as well as minimize your global taxation.  Our firm’s extensive experience in international transactions enables us to provide planning for domestic corporations with foreign activities and foreign corporations with U.S. activities.  In addition, we can provide guidance in solving complicated foreign transactions involving both U.S. and foreign tax laws.

We are highly skilled in assisting domestic and foreign investors with the acquisition and selling of domestic and foreign businesses.  The expansion and globalization of trade and investment, increased mobility of capital, the removal of no tax barriers to international commerce and investment, and the integration of national economies have led to the reduction of tax barriers to capital flows and to the modernization of tax systems by other countries.  This has also led to increased development of capital and financial markets, increased competition between multinational enterprises. We help investors with the development of new methods to minimize tax, and the exploitation of new opportunities by developing tax policies that divert the location of capital from high tax jurisdictions.

Our professionals have extensive experience in guiding partnerships, limited liabilities and other pass through entities through the difficult tax rules that govern these types of entities, particularly they relate to distributions and allocations, and structuring creative solutions to the complex tax issues.

Transfer pricing has taken on significant importance due to foreign governments’ involvement in international/global trading, and it is essential to defend our clients against proposed inter-company allocations.  A growing issue for many multinational corporations is the prospect of a related party pricing adjustment from an Internal Revenue Service (IRS) examination team.  This issue is becoming more prevalent due to the potential double taxation of taxpayers entitled to treaty benefits.  Our experience in IRS negotiations allows us to act as a mediator and facilitate communication and resolution in IRS examinations.

We can also assist in the prevention of these types of examinations by initiating an Advanced Pricing Agreement (APA).  An APA will reduce a company’s exposure to transfer pricing penalties and will prevent the triggering of the penalty interest provision. We can assist in the pre-filing conferences with the IRS as well as prepare the transfer pricing methodology proposal.

The increasing significance of electronic commerce has brought further speculation to cross-border transactions involving technology.  Because of inconsistencies in the regulations, double taxation remains a problem for U.S. software exporters competing in foreign markets.  We provide consultation in structuring copyright right and technology transactions in order to provide the client with the most favorable tax treatment by preventing the triggering of withholding and other taxes.

Our in-depth knowledge of how tax treaties affect international transactions gives us an advantage over many other firms.  Many multinational corporations are faced with federal taxation involving international issues that include foreign tax credits (FTC), U.S. source income, and transfer pricing.  We can assist in the allocation of tax attributes among controlled corporations, which is an issue of domestic taxation affecting many corporations.

We provide services relating to custom and excise duties.  Our diagnostic review helps identify areas of potential exposure and tap opportunities for tax savings.  We advise on a wide range of custom procedures and documentation requirements including those relating to import and export of goods, clearance of imports and warehousing.  We provide the necessary guidance to enable our clients to make the most of various benefits available to specific entities.

There are extensive reporting and disclosure requirements with respect to US companies who operate businesses in foreign countries and foreign companies operating businesses in US.  We assist companies to comply with all reporting requirements to avoid any civil and criminal penalties.  Civil and Criminal penalties (up to $500,000 or 10 years imprisonment) are provided for failure to report or for filing a fraudulent report.