Global tax and effective tax rate planning, inbound and outbound investments
We provide full M&A structuring, and analysis and re-structuring consulting, to achieve business and financial goals, including worldwide effective tax rate planning. Our services include tax loss and basis maximization for asset or stock sales, goodwill and intangibles analysis, pre- and post-acquisition valuation and purchase price allocations, as well as specialized projects for either buy- or sell-side (U.S. and foreign entity structuring, Private Letter Rulings, E&P studies and Sec. 382 studies).
Our foreign affiliate offices in over 100 countries (Europe, Asia, Latin America), arrange for foreign jurisdiction statutory audits, tax compliance, indirect tax (VAT) consulting, and our relationships with our foreign affiliate offices results in a more seamless process than national firms.
We provide ongoing consulting and planning regarding cash repatriation (dividend) planning, as well as withholding and foreign tax credit consulting.
Our partners have deep expertise in specialty international tax situations, such as the special structuring required for foreign investment in U.S. real estate, Canada and Mexico cross-border tax effects, U.S. exporter benefits (IC- DISCs and customs opportunities), and many others.
Many clients engage us as a fully outsourced tax department, including full compliance (income tax, sales tax, etc.) services, and as-needed planning/consulting services. Having broad U.S. GAAP and IFRS knowledge and direct experience results in high-level tax accounting services, such as ASC 740 and FIN 48 planning, documentation, and compliance.
Our partners have years of transfer pricing consulting and practical experience, in both serving and working for multinational companies. They assist clients in developing regulatory compliant and tax-efficient structures, preparing for audit, appeal, or competent authority proceedings, resolution of transfer pricing disputes, and decreasing transfer pricing exposure in future periods.
Typical deliverables to clients include specific consulting (individual intangibles, product lines, subsidiaries, business functions, etc.) to full studies. The firm currently relies on Bureau Van Dijk for comparable searches worldwide and related financial information.
For expatriate or impatriot employees, we provide tax planning and compliance in addition to employer foreign tax policy consulting. Global tax responsibility is one of the major expenses associated with international assignments. For example, employees may be subject to taxation and reporting requirements in several different locations and these tax obligations often continue long after an assignment is complete – driven by equity awards, other forms of deferred compensation, and tax equalization settlement payments.
Our International Assignment Services team can provide tax compliance and related consultation services in the U.S. and foreign countries around the globe for inbound and outbound assignees.
If you’re interested in learning more about our international tax services, or to speak with one of our partners about how we can help your international business, contact us today.