International Tax Services
The U.S. market offers tremendous opportunities for foreign-owned businesses. But to successfully capitalize on these opportunities also means understanding and navigating a complex array of tax issues at the federal and state and local levels. Thus, there are some common questions you must answer:
- Will your operation rise to the level of a permanent establishment?
- Should you form a U.S. subsidiary and, if so, what form of entity best fits your strategy?
- How will you structure your capital? Can you have too much debt?
- Will there be related-party transactions? Do you need a transfer pricing analysis and documentation?
- Do you understand your full range of compliance and reporting obligations?
- If you have a permanent establishment, what about your employees? Do you have appropriate policies in place to help them understand and address their tax needs?
- Will your U.S. operations create state and local tax obligations? In which jurisdictions? What will you need to file, and where?
- Corporate Structuring and Reorganization
- Anti-Deferral Strategies
- Foreign Tax Credit (FTC) Utilization
- Tax Treaty Interpretation and Planning
- International M&A and Group Reorganization
- Transfer Pricing
- VAT Advisory and Compliance
- FATCA
- Withholding Tax Due Diligence
- Base erosion and profit shifting (BEPS)
- Cross-border employees
- Earnings and profits and tax pool studies
- Foreign tax credit maximization
- Permanent establishment
- Subpart F and cash repatriation strategies.
- Inter/intra-company financing – – Associated interest rates for inter and intra company loans.
- Transfer pricing
- Withholding taxes