International Tax

Before signing any agreements for a strategic acquisition, your business should assess the tax implications of the transaction and envision the process for integrating the acquisition into your existing operations.

Project effective tax rates, understand indemnities related to tax issues, and prepare for the due diligence process so your business can hit the ground running once you’ve acquired the new venture. Prepare for any transaction stipulations including collateral required by banks and its potential taxable income, as well as unexpected tax bills once businesses are integrated.

Whether you’re on the buy- or sell-side of an international transaction, execute the deal knowing you’re prepared for the full potential impact.

Structure transactions strategically, uncover risks early, and analyze potential value with proper due diligence.

• Buy-side
• Sell-side
• Quality of earnings
• IT assessments

Tap into incentives provided by the US government to expanding exporters by using a Domestic International Sales Corporation (DISC) and evaluating the potential for the foreign-derived intangible income (FDII) deduction.

Evaluate and implement export strategies with our guidance each step of the way to understand ever-changing regulations and file your tax return. We can also make legal referrals as needed.

Drastically reduce your company’s effective tax rates by avoiding double taxation from multiple jurisdictions.

Design a tax structure that integrates within your operational structure while taking advantage of efficiencies and opportunities, such as utilizing check-the-box elections and reevaluating transfer pricing policies.

Reduce your taxes and tax rates by executing business plans that account for tax consequences of redeploying intangible property.

Companies that don’t understand the tax ramifications of their business strategies will likely face numerous IRS queries that could result in exit taxes and penalties related to intellectual property—and even inadvertently move the business to an unfavorable tax jurisdiction.

It’s crucial for US companies or individuals disposing of non-US business or investment assets to identify the after-tax rate of returns. How you structure your dispositions can determine the difference between a poor or profitable investment.

Attention should be paid to:

• The character of gains or losses
• The ability to use foreign tax credits
• The availability of tax treaty benefits
• The disclosure requirements
• The impact on your international financial statements

Avoid significant penalties that can arise when the numerous foreign disclosure forms required for transactions involving non-US assets aren’t properly submitted.

Maintain cash flow and reduce your tax rates by addressing one of the most important considerations for non-US companies disposing of US real estate: withholding under the Foreign Investment in Real Property Tax Act (FIRPTA).

FIRPTA often imposes a withholding tax on gross proceeds of a sale that can impair the seller’s liquidity.

Deduct foreign operation and built-in offshore losses in the United States through trapped and deferred loss planning.

Proper planning can help you manage your cash flow, overall tax liability, and effective tax rate for financial statement reporting purposes while helping your bottom line.

Make informed operational business decisions during transitions knowing you’ve considered all potential tax consequences—whether you extract an underperforming business unit for disposition, acquire a company, or rationalize your current organizational structure.

Strategically structure transactions so you can move assets or business units across borders tax-free or in a tax-deferred or tax-efficient manner.

Avoid the potential consequences that could affect your global operations and bottom line if you structure transactions incorrectly or don’t take specific tax considerations, such as the nuanced rules of Section 367, into account.

Tap into the potential of your workforce by designing a strategy that delivers a return on the investment you make in your people. Operating in a global marketplace can present many challenges related to your workforce including:

• Expatriate benefits
• Federal and state taxes
• Tax equalization calculations