Tax Services Overview: International
Choice of Entity – We evaluate and discuss the best type of entity to use
when clients begin to do business internationally. This planning can allow the use
of the international losses in the United States or minimize the U.S. tax on the
international business.
Structuring of Transactions – We develop and evaluate ideas and planning
for the structure of international transactions to minimize taxes. This can involve
research, analysis and preparation. We also have contacts in many countries to assist
on the foreign side of the transaction.
Aliens and Expatriates – We have staff trained in preparing individual tax
returns for both U.S. residents working abroad as well as foreign expatriates working
in the U.S. We prepare these returns according to current IRS rules and ensure that
all credits and deductions that are available to our clients are correctly reported
in their return. In addition, we advise clients making payments to such individuals
as to their withholding requirements for foreign residents working in the United
States.
Transfer Pricing – The IRS has power to reallocate income, deductions and
other tax items among commonly controlled businesses in order to prevent evasion
of taxes. The IRS is especially alert to situations where income is being shifted
outside the United States. The transfer pricing rules are extremely complicated
and it can be difficult to determine when and how they apply to specific transactions.
We advise our clients of issues to consider when examining and determining their
inter-company pricing policies in order to minimize the risk of challenge. We can
also assist clients in arranging for a transfer-pricing study to be done by a third-party,
which can further reduce the risk of challenge.