Whether your business has foreign operations, foreign ownership or foreign subsidiaries, there are complex rules and reporting requirements that must be followed. We can help you understand the U.S. tax consequences related to multinational businesses, prepare required U.S. tax return disclosures, and assist with various projects, including transfer pricing; foreign tax credit optimization; review of treaties; and accounting for income taxes. If your business is considering an expansion into a foreign country or a transaction that could create a tax liability or reporting requirement in that foreign country, we can provide technical assistance on foreign tax matters.
- Successful defense with IRS of transfer pricing documentation for multinational manufacturing company, with particular focus on management fees.
- Development and successful implementation of restructuring plan for global organization resulting in minimization of worldwide income taxes, including effective location of debt.
- Detailed calculation in connection with foreign subsidiaries' unremitted earnings, Subpart F considerations and investment in U.S. property.
- Coordination of reporting requirements for "secondment" arrangements covering various foreign nationals, including preparation of required U.S. individual income tax returns.
- Analysis of anti-deferral provisions and creation of alternative structures for investment entity, including effective use of check-the-box provisions.
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