International Tax

For foreign entities entering the U.S. market we help coordinate business activities by establishing and optimizing import/export deals, avoiding a U.S. taxable presence, or creating an entity. We also support inter-company transactions through collaboration with our Transfer Pricing practice.

We help public and private U.S. entities entering foreign markets. Services we provide include:

• Coordination with foreign offices/affiliates
• Foreign tax credit (FTC) planning
• Anti-deferral regime avoidance
• Controlled Foreign Corporation (CFC)
• Subpart F Income Minimization
• Global Intangible Low-Taxed Income (GILTI)
• Passive Foreign Investment Company (PFIC)
• Earnings and profits (E&P) and dual consolidated loss (DCL) accounting

Whether an inbound or outbound entity, we assist private equity, venture capitalists, asset managers, and other investment groups explore and enter global markets. In addition, we help foreign flow through entities invest in U.S. businesses and capital markets.

We assist employers in sending employees abroad (expats) or having foreign employees enter the U.S. (impats). Our services include developing global compensation plans, including pensions, deferred compensation, and stock options; and hypothetical tax computation (hypo-tax) to confirm employers and employees are taking full advantage of totalization agreements.

Our phased approach helps public and private multinationals achieve a tax-efficient supply chain. Services are customizable to each level of a company’s life cycle and are performed in conjunction with our Transfer Pricing practice to confirm functions and profit allocations are appropriate.

Targeted support for the international tax aspects of ASC 740 whether this be from an accounting or audit perspective. Our scope includes audit, review, or accounting for:

• ASC 740-10-25-3 (fka APB 23)
• ASC 740-10 (fka FIN 48)
• Tax accounting for global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), Subpart F, DCL, etc.

We also provide assistance with foreign provisions in determining permanent and temporary items.

We assist taxpayers with international tax audits as well as submission to IRS programs, such as the streamlined filing compliance procedures, Delinquent International Information Return Submission Procedures (DIIRSP), handling specified procedures for waiver requests and delinquent IRS Form 1120-F, and other IRS matters.

Consulting services involve assisting clients with value added taxes (VAT), Goods & Services Taxes (GST/HST/PST), and U.S. customs and duties. We also coordinate with a foreign office – whether an MGO affiliate, foreign law firm, or foreign accounting firm. Our compliance support focuses on assisting clients with foreign compliance calendars.

Consulting support includes OECD Pillar Two modeling for clients and assistance with planning for minimization of worldwide taxation. These services strictly involve income or direct taxes. Our compliance services focus on assisting clients with foreign compliance calendars.

Through our Private Client Services offering, you can close the gap between yourself and cross-border activities. Whether you’re a U.S. citizen with foreign assets or a foreign individual with U.S. assets, our approach includes income tax minimization and transfer tax minimization techniques.

Areas of focus include:

• Global family office
• Relocation services
• Business affairs structuring
• Foreign assets disclosure and management
• International income tax planning
• International estate (transfer) tax
• IRS Voluntary Disclosure Program

We provide a wide range of industries with guidance for specific nuances in international tax, including tax-exempt entities, entities operating in the cannabis space, as well as reviewing OECD matters and their implications.