International Tax
Moss Adams assists clients with international trade requirements, NAFTA transactions, evaluating trade profitability, international EDI and telecommunications consulting, structuring, transfer pricing, and conducting due diligence for foreign investments. Our International Business Services Group is led by professionals who have both technical and hands-on experience in serving international clients.
More than 500 of our clients trade internationally, or operate offshore subsidiaries or joint ventures. We can support all aspects of our clients’ international businesses, including foreign taxation, financing arrangements, sourcing, import/export considerations, and new markets.
Transfer Pricing
Clients with foreign affiliates who enter into transactions for goods and services with each other are subject to transfer pricing rules. The rules require that companies adequately document the pricing policies of their inter-company transactions. The rules also stipulate how arm’s length prices should be established. Clients who do not abide by applicable transfer pricing laws are subject to additional taxes and possible severe penalties. (Canada is taking an extremely aggressive position to enforce their transfer pricing laws).
A client that can benefit from transfer pricing:
- Is a domestic corporation (whether or not ultimately U.S.-owned); and has international cross-border transactions (involving tangible personal property, royalties, or services) with related parties, where the U.S. is one of the countries involved; and
- Has annual revenue of at least $30 million; and
- Is not ultimately owned by a Japanese parent corporation; and
- Has more than $10 million in value of international cross-border transactions with related parties.
A client that can benefit greatly from this service:
- Has two or more foreign affiliates (e.g., branch, CFC, joint venture, partnership); and/or
- Is a domestic corporation that is the ultimate parent of a controlled/consolidated/affiliated group; and/or
- Is a domestic corporation that is ultimately foreign owned; and/or
- Has thousands of international cross-border transactions with related parties; and/or
- Has been contacted by the IRS or a foreign taxing authority regarding audit activities; and/or
- Has a small or non-existent international tax staff or department; and/or
- Is not a subsidiary of a U.S. controlled/consolidated/affiliated group.
International Tax Contacts
Washington
Bill Braunberger
360-685-2218
Michael Ferguson
206-302-6506
Mark Christopher
206-302-6477
Oregon
Paul Waldram
503-478-2232
California
Bill Armstrong
949-221-4077
Jim Pope
858-627-1466
Michael Ozen
310-477-0450
