Tax agencies from federal to local jurisdictions have become more aggressive in order to generate tax revenue. This has resulted in an increased number of audits in both U.S. multi-national companies and U.S. subsidiaries of foreign companies doing business in the U.S., all of which have complex reporting requirements. Therefore, it has become vital for growing businesses to have dependable representation before taxing authorities.
In the first critical stage, we meet with International Examiners, respond to letters, and mediate cases on the clients’ behalf. If necessary, litigation may be avoided through a Mutual Agreement Procedure (MAP), under which the taxpayer may request competent authority assistance when he believes the actions of the U.S. and/or the treaty country will result in taxation contrary to the treaty. Our strategy is to effectively settle international and domestic tax issues with various tax agencies without interrupting our clients’ business.
Letter rulings offers a business certainty as to how the Internal Revenue Service (IRS) views the anticipated transaction and what tax treatment the business can expect from the IRS, based on the specific facts presented in the Private Letter Ruling (PLR). PLRs can be very useful to companies contemplating business transactions. If the ruling is unfavorable, the company has an opportunity to select an alternative tax strategy without incurring costly tax consequences. We have extensive knowledge of, and experience in, planning and preparing PLR documents for our clients.
We represent both domestic and multinational clients in seeking to secure or recover assets which involve complex settlement negotiations. During the process, we analyze relevant financial issues, restructuring options, and other opportunities, including the most practical way to liquidate a business.
Complex multinational transactions increase the potential risk of fraud: a major concern for company management. Businesses need to plan the most efficient way to safeguard their assets and integrity from both internal and external white-collar crimes. A recovery strategy plan is also needed to avoid further loss.
With our experience in forensic accounting, financial regulation, and risk management, our risk assessment service can identify high risk areas and develop an implementation plan. Working closely with law firms, we provide our clients with fraud investigation and dispute settlement services.