The expansion and globalization of trade and investment has led to reduced tax barriers to capital flows and modernized tax systems by other countries. This in turn has increased the development of capital and financial markets, as well as competition between multinational enterprises. We develop tax policies that divert the location of capital from high tax jurisdictions, and are highly skilled in assisting with the acquisition and selling of domestic and foreign businesses.
The complex world of offshore business involves dealing not only with tax havens but also with onshore high tax countries competing to attract multinational companies with tax planning opportunities. We can help plan tax structure to improve overall tax efficiency. This includes finding tax planning opportunities in tax treaty planning relating to passive income, establishing holding companies, and other passive investment activities.
Due to inconsistencies in regulation, double taxation remains a problem for U.S. software exporters competing in foreign markets. The explosive growth of electronic commerce has left irregular variation in cross-border transactions involving technology. We provide consultation in structuring copyright and technology transactions in order to provide clients with the most favorable tax treatment, thereby preventing the triggering of withholding and other taxes.
We resolve clients’ transfer pricing issues at all levels of the process, from initial tax authority inquiries through administrative appeals. 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 future business risk and avoid litigation, we help guide our clients into an Advance Pricing Agreement (APA) with one or more tax authorities. We also prepare requests for competent authority if necessary.
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 the foreign countries in which they operate. We help clients improve overall compliance efficiently and assist with transparent reporting requirements for various tax agencies.
Our extensive experience with foreign tax agencies gives us an advantage over many other firms in structuring transactions so clients can receive full treaty benefits. Many multinational corporations are faced with complex federal taxation involving international issues, such as foreign tax credits (FTC), U.S. source income, transfer pricing, and tax treaties. We assist clients in making requests for competent authority in case of disputes with foreign tax authorities.
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.