International Services

Overview

To stay competitive and expand multinational business in a swiftly changing world economy, a business must carefully manage a global effective tax rate including local taxes. This also presents a great opportunity for a business to maximize tax cash savings to help business grow. Well-planned tax strategy should be integrated and flexible to meet future global economic and legislative changes. We can provide guidance in planning and solving complicated foreign transactions involving both U.S. and foreign tax laws.

Inbound and Outbound Compliance

As multinational companies enter into more complex transactions, they are faced with ever-changing rules and more rigorous enforcement by tax authorities in both the U.S. and in foreign countries in which they operate. We can help clients improve overall compliance efficiently and assist with transparent reporting requirements for various tax agencies.

Cross-Border Acquisitions

The expansion and globalization of trade and investment, the 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 and to increased competition between multinational enterprises. We are highly skilled in assisting domestic and foreign investors with the acquisition and selling of domestic and foreign businesses. We can also help investors with the development of new strategies to minimize tax, and with the exploitation of new opportunities by developing tax policies that divert the location of capital from high tax jurisdictions.

Technology Transfer

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 and technology transactions, in order to provide clients with the most favorable tax treatment by preventing the triggering of withholding and other taxes.

Transfer Pricing

Transfer pricing continues to be a prime focus of tax authorities around the world as multinational companies enter into complex related party transactions. To minimize the risk of related party pricing adjustment and possible penalty from tax authorities, companies need well-planned and prepared transfer pricing documentation. We assist clients in resolving transfer pricing examination issues at all levels of the process, from initial tax authority inquiries through administrative appeals. To minimize future business risk and avoid litigation, we can assist clients to enter into Advance Pricing Agreement (APA) with one or more tax authorities. We also prepare requests for competent authority if necessary.

Tax Treaty

Many multinational corporations are faced with federal taxation involving international issues that include foreign tax credits (FTC), U.S. source income, transfer pricing, and tax treaties. Our extensive experience in dealing with foreign tax agencies gives us an advantage over many other firms in structuring transactions to ensure that clients can receive full treaty benefits. We also assist clients in making requests for competent authority in case of disputes with foreign tax authorities.

Offshore

The complex world of offshore business involves dealing not only with tax havens but also with onshore high tax country competing to attract multinational companies with tax planning opportunities. Some of the tax planning opportunities include tax treaty planning relating to passive income, establishing holding companies, and other passive investment activities.

Effective tax planning is dependent on many issues including controlled foreign company and management control tests and provisions, transfer pricing anti-avoidance provisions, capital gains tax, and exchange of information treaties and provisions. We can help plan tax structure to improve overall tax efficiency.

IFRS

The globalization of capital markets and the multinational structure of business organizations have brought about the need for international accounting standards. The economies of virtually every country in the world have become increasingly interdependent due to international business developments. The flow of accounting reports across national borders produces an urgent need for international uniformity in accounting. We have in-depth knowledge of international accounting standards (IFRS) and can assist companies that conduct businesses in multiple countries.