Whether you’re a corporation with overseas operations or a business or individual needing to work out taxation of U.S. residents working abroad or foreign citizens working in the U.S., we can help you plot a course through cross-border taxation issues
Multi-national businesses have special challenges and risks, whether based inside or outside of the United States. Let us help you navigate such complicated issues as:
- Expanding out of or into the US
- Selecting the right holding company
- Transfer pricing, planning and compliance
- Sourcing of income and foreign tax credits
- Inter company agreements, including:
- Cost sharing and “offshoring” technology
- Contract research and development
- “Cost plus” arrangements
- International tax audits
- VAT and GST considerations
- Foreign tax withholding and treaty issues
- US compliance (Forms 5471, 1118, 5472, etc.)
- Dividend repatriation policy
- Cross-border mergers and acquisitions
- Review of US multi-state consequences
- FIN 48 analysis and reports
- Expatriation Filings (I.R.S. form 8854) and related analysis