International Tax

 

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
  • Intercompany 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