Outbound International Tax Planning & Compliance

Many US individuals and businesses today look to expand their business across our borders. Our goal is to help these individuals and businesses understand the nuances of the international tax rules and also help them plan to mitigate any negative tax consequences as a result of doing business abroad. It is also especially important that these individuals and businesses properly disclose and report their operations abroad. Failure to do so can result in significant penalties and unexpected negative tax consequences.

The new tax reform under the Tax Cuts and Jobs Act has also significantly impacted US companies with operations abroad. It is important to know how these changes affect your business and take the necessary steps to mitigate any negative tax consequences as a result of these changes. We have experience assisting clients that invest outside the US and can help with the following issues:

Tax Planning & Restructuring to Minimize Negative Tax Implications of the 2018 Tax Reform (TCJA)

New tax reform under the TCJA brought significant changes to international tax. These changes have made it especially hard for taxpayers to defer their foreign income due to the introduction of GILTI, an additional anti-deferral regime.

We can help with the following:

  • Section 965 (Repatriation tax) analysis and reporting

  • Tax planning to minimize negative tax consequences as a result of the new GILTI rules.

  • Review of new CFC ownership rules

Acquisition and disposition of non-us investments

Prior to starting business abroad, it is important that taxpayers also factor in the US tax consequences and filing requirements associated with their investment abroad. The US tax law is especially punitive to US persons that control companies abroad. Our job is to analyze these investments and make sure they are structured properly to minimize your worldwide tax. If you are paying taxes abroad, our goal is to make sure you can maximize these credits in order to reduce your US tax liability.

We can help with the following:

  • Tax structuring to mitigate double taxation

  • Section 338 basis step-up analysis on the acquisition of a foreign business

  • Foreign tax credit utilization and planning

  • Planning to mitigate negative consequences as a result of anti-deferral regimes (subpart F, PFIC and GILTI rules) upon exit

  • Controlled Foreign Corporation analysis and applicability of attribution rules

international tax - compliance

For taxpayers doing business internationally, it is very important that their foreign income and assets are properly reported. Failure to do so can result in significant penalties that the IRS can and will impose on a taxpayer. Our goal is to analyze our client’s investments abroad and make sure that they properly disclosing these investments on their income tax returns.

We can help with the following:

  • FATCA compliance and implementation

  • Foreign Asset Reporting (FBAR - Form 114 and Form 8938 - Statement of Specified Foreign Financial Assets)

  • Foreign filing return preparation and review (Forms 5471, 8865, 8858, 8621, 5472, 1120-F)

  • US withholding tax return compliance (Form 1042/1042-S and Form 8804/8805)

  • Section 987 fx gain/loss computations on remittances from foreign branches and partnerships

  • Analysis and computation of subpart F and GILTI

  • E&P studies