Inbound International Tax
Planning & Compliance

Our goal is to help you understand the intricacies of the US tax law and help you minimize your tax exposure in the US. We have extensive experience with various inbound tax issues and can assist with the following issues many non-US persons and companies looking to do business in the United States face:

Tax Structuring for the Acquisition and Disposition of U.S. Real Estate by non-US persons

It is important that the acquisition of US real estate by a non-US person is properly structured. Proper structuring can result in significant tax savings in the long run. Additionally, non-US persons also want to make sure they get the most money on their exit. Our firm can analyze the tax issues relating to the acquisition and disposition of US real estate and assist with any planning and compliance needs you may have.

We can help with the following:

  • Pre-acquisition structuring to minimize taxation and withholding in the US.

  • Implementation of leveraged real estate fund structures by non-US persons.

  • Preparation of income tax returns for both individuals and companies.

  • Compliance with Foreign Investment in Real Property Tax Act (“FIRPTA”) withholding requirements.

Pre-immigration Tax Planning & Compliance Services

If you are planning to move to the United States, it is critical that you are aware of all of the tax implications related to your move here. What some foreigners may not know is that the US taxes their residents and citizens on worldwide income. Additionally, merely being physically present in the United States for a certain amount of time can cause a non-US person to be treated as a US resident. Thus, subjecting an unsuspecting person to taxation on their worldwide income. Proper tax planning can save you both time and significant money on taxes in the long run. The US tax rules are extremely complicated and our approach is to review all of your facts (income, ownership, assets, etc.) so that we can provide you with the proper tax advice in order to properly re-structure your non-US investments and assets before you move here.

We can help with the following:

  • Pre-immigration tax planning, including review of your current worldwide structure and assets and advising on restructuring to minimize double taxation and utilization of foreign tax credits.

  • Preparation of US Individual Tax Returns & necessary information returns.

Foreign Companies Doing Business in the United States

Non-US companies and individuals are generally taxed in the US on their US sourced income. Our goal is to help these companies and individuals be in compliance with their US tax returns and also help them minimize their tax liability here in the US. For those that are residents in a treaty country, we can assist with reducing or exempting tax through the use of an income tax treaty.

We can help with the following:

  • Tax compliance services for non-US companies (Form 1120-F).

  • Tax Treaty Planning & Analysis.

  • Tax Planning & Structuring .

  • Review and preparation of Form W-8.

Outbound International Tax Planning & Compliance

Many US individuals and businesses today look to expand their business across our borders. Our goal is to help these individuals and businesses understand the nuances of the international tax rules and also help them plan to mitigate any negative tax consequences as a result of doing business abroad. It is also especially important that these individuals and businesses properly disclose and report their operations abroad. Failure to do so can result in significant penalties and unexpected negative tax consequences.

The new tax reform under the Tax Cuts and Jobs Act has also significantly impacted US companies with operations abroad. It is important to know how these changes affect your business and take the necessary steps to mitigate any negative tax consequences as a result of these changes. We have experience assisting clients that invest outside the US and can help with the following issues:

Tax Planning & Restructuring to Minimize Negative Tax Implications of the 2018 Tax Reform (TCJA)

New tax reform under the TCJA brought significant changes to international tax. These changes have made it especially hard for taxpayers to defer their foreign income due to the introduction of GILTI, an additional anti-deferral regime.

We can help with the following:

  • Section 965 (Repatriation tax) analysis and reporting

  • Tax planning to minimize negative tax consequences as a result of the new GILTI rules.

  • Review of new CFC ownership rules

Acquisition and disposition of non-us investments

Prior to starting business abroad, it is important that taxpayers also factor in the US tax consequences and filing requirements associated with their investment abroad. The US tax law is especially punitive to US persons that control companies abroad. Our job is to analyze these investments and make sure they are structured properly to minimize your worldwide tax. If you are paying taxes abroad, our goal is to make sure you can maximize these credits in order to reduce your US tax liability.

We can help with the following:

  • Tax structuring to mitigate double taxation

  • Section 338 basis step-up analysis on the acquisition of a foreign business

  • Foreign tax credit utilization and planning

  • Planning to mitigate negative consequences as a result of anti-deferral regimes (subpart F, PFIC and GILTI rules) upon exit

  • Controlled Foreign Corporation analysis and applicability of attribution rules

international tax - compliance

For taxpayers doing business internationally, it is very important that their foreign income and assets are properly reported. Failure to do so can result in significant penalties that the IRS can and will impose on a taxpayer. Our goal is to analyze our client’s investments abroad and make sure that they properly disclosing these investments on their income tax returns.

We can help with the following:

  • FATCA compliance and implementation

  • Foreign Asset Reporting (FBAR - Form 114 and Form 8938 - Statement of Specified Foreign Financial Assets)

  • Foreign filing return preparation and review (Forms 5471, 8865, 8858, 8621, 5472, 1120-F)

  • US withholding tax return compliance (Form 1042/1042-S and Form 8804/8805)

  • Section 987 fx gain/loss computations on remittances from foreign branches and partnerships

  • Analysis and computation of subpart F and GILTI

  • E&P studies

Expatriate tax Compliance Services

The United States taxes its residents and citizens on worldwide income and requires its US citizens living abroad to file and report income annually. If you are a US citizen currently living abroad, it is equally important that you also properly file and disclose your non-US assets as well. We have experience assisting many US citizens currently living abroad and our goal is to make sure that their foreign income and non-US assets are properly reported while at the same time double taxation is minimized in the US. Expatriates can generally reduce their US tax liability through the use of the foreign earned income exclusion or foreign tax credits. Under the foreign earned income exclusion, expatriates may exclude up to $103,900 (2018) of earned income annually. We make sure to review all of your facts and circumstances to make sure that the foreign earned income exclusion is fully utilized as well as any other foreign tax credits you may have.

We can help with the following:

  • Preparation of US individual tax returns and foreign filings for those living abroad.

  • Review and utilization of the foreign earned income exclusion and foreign tax credits.

  • Tax Equalization calculations for expats.

Streamlined Filing Compliance Procedures - Filing of Delinquent Tax Returns

In 2012, the IRS introduced the Streamlined Filing Compliance Procedures as an alternative option to the more punitive Offshore Voluntary Disclosure Program (OVDP). This program is intended for US persons (living either inside our outside of the US) that have failed to file income tax returns and disclose their foreign financial assets in the past as a result of non-willful conduct on their part. US persons living inside the US that enter into this program will be subject to a 5% offshore penalty. Whereas, US persons living outside of the United States is not subject to these penalties.

The IRS requires that those filing under the Streamline Filing Compliance Procedures complete 3 years of delinquent federal income tax returns and 6 years of Foreign Bank Account Reports (FBAR).

We can walk you through the details of the Streamline Filing Compliance Procedures and help prepare the necessary tax returns and FBARs needed for the program. Please reach out to us to learn more.

Additional information relating to the Streamlined Filing Compliance Procedures can be found directly on the IRS website here