International Tax

Structuring of Acquisitions / Dispositions

Ensure an optimal tax position and maximized global cash flow with your acquisition, sale, or reorganization of a U.S. or foreign target, or subsidiary.

Repatriation Planning

Minimize the tax impact to your bottom line of repatriating funds in a post-Tax Cuts and Jobs Act environment.

Foreign Tax Credit Planning

Analyze available foreign tax credits to mitigate the potential for double taxation. Even post-tax reform, there may be opportunities to minimize your overall tax liability.

Legal Entity Rationalization / Restructuring

Identify opportunities to eliminate or realign legal entities to eliminate unnecessary costs and help ensure that your organizational structure continues to meet business goals.

Transfer Pricing

Identify strategies to minimize exposure to price adjustments and tax penalties for trade between related legal entities in your multinational organization.

Navigate the hurdles of conducting business on an international basis as a U.S. multinational, and mitigate the risk of being out of compliance with the ever-increasing complexity and reach of current tax rules and regulations.

U.S. and non-U.S. Tax Audits

Receive assistance with IRS audits of U.S. and foreign subsidiaries and be better prepared to defend your tax position, practices, and compliance.

Flow-Through Restructure

Understand the income inclusion and deductions under the Foreign Derived Intangible Income Deduction (FDII) and the Global Intangible Low-Taxed Income (GILTI) provisions to identify opportunities to realign your entity structure and gain a more favorable tax position.

International Tax Compliance Review

Review international tax compliance filings and processes to ensure that organizations have not missed information return filings (e.g. Forms 5471 / 8858 / 8823) which could result in the assessment of severe monetary penalties per violation. This includes gaining an understanding of the potential impact on the Statute of Limitations.

Foreign Vendor Reporting Review

Ensure that proper documentation is obtained and forms are submitted that permit companies to withhold tax at a lower rate (or none at all) on payments made to settle foreign invoices. Failure to do so may leave you liable for a 30% withholding tax if you’re acting as the withholding tax agent.

IC-DISC

Analyze the tax savings opportunities that may be available to you—even post-tax reform—if you produce and distribute U.S. made products that are used abroad.