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INTERNATIONAL TAX

More and more companies are going global

Companies are finding it is easier than ever to do business abroad. Along with the opportunity for increased revenue, profit and jobs, doing business abroad brings more complexities to your tax planning and compliance. International companies are increasingly impacted by tax, legislative and regulatory developments not just from the United States but the international marketplace.

That’s why if you are conducting business internationally or are looking at the possibility of going global, you need a trusted business advisor that can assist you and your team to proactively plan and manage your international tax commitments.

Our team of professionals, along with international resources from the Leading Edge Alliance, can help you and your team to strategically develop a plan that integrates your business and tax strategies to mitigate your tax liabilities. Leading Edge is the second largest alliance of accounting firms. Working with Leading Edge firms helps us to provide additional solutions that are typically only delivered by national firms. To learn more about LEA Global, Click here.

MarksNelson provides the following international tax services:

Domestic International Sales Corporations (IC-DISC)
Foreign Business Expansion
International Tax Structuring
Inbound & Outbound Compliance and Consulting
Expatriate Compliance and Consulting
FATCA Compliance
Transfer Pricing


Service Overview

IC-DISC

The Interest Charge – Domestic International Sales Corporation (IC-DISC) is a tax-exempt entity serving as a tax deferral strategy since 1984. It is particularly beneficial to mid-sized businesses exporting their products and services.

IC-DISC can help you:

Achieve permanent tax savings on global sales
Increase liquidity for shareholders of business
Leverage the cost of capital
Create opportunities to manage incentives
Defer income into future years

Our approach to IC-DISC engagements is designed to maximize the potential benefit by analyzing your foreign sales structure and then developing the appropriate commission agreement.

Foreign Business Expansion

Deciding where to expand is as critical as your decision to expand. Because each country has vastly different tax structures, it’s imperative to work with your accountant in advance to determine:

The correct tax structure
Financing
Indirect taxes
Audit requirements
Exit strategy
Other local tax and business idiosyncrasies

International Tax Structuring

How you structure your organization before you start operating and paying taxes oversees is critical. Choosing the proper structure means knowing the tax implication of the decision and how it fits within the organization’s business plan.

MarksNelson professionals can help you to set up a:

Branch office
Subsidiary
Disregarded Entity
Stand alone entity
Or change your current structure

Inbound & Outbound Tax Consulting

Is your sale subject to Value Added Tax (VAT)? Is there a more favorable way to structure transactions to minimize VAT? How do you handle additional time and risk associated with collecting accounts receivables abroad? MarksNelson can assist you with all of these international tax issues.

FATCA Compliance

The Foreign Account Tax Compliance Act (FATCA) is an effort to expand tax compliance involving foreign financial assets and offshore accounts.

Under FATCA, U.S. taxpayers with specified foreign financial assets that exceed certain thresholds must report those assets to the IRS. This reporting will be made on Form 8938, which taxpayers attach to their federal income tax return.

In addition, FATCA will require foreign financial institutions to report directly to the IRS information about financial accounts held by U.S. taxpayers, or held by foreign entities in which U.S. taxpayers hold a substantial ownership interest.

Under FATCA, withholding agents must withhold tax on certain payments to foreign financial institutions (FFIs) that do not agree to report certain information to the IRS about their U.S. accounts or accounts of certain foreign entities with substantial U.S. owners.

Expatriate Services

Working or living abroad can be challenging especially if you need to prepare both a domestic tax return and one for the country in which you are living or working. At MarksNelson, our international tax team not only helps you with compliance aspects, but also with your personal tax planning. Our international tax services for individuals include:

Expatriate Compliance
Expatriate Consulting
Foreign Bank Account Reporting
Equalization Compliance
Repatriation Consulting

Transfer Pricing

If you are selling or buying product across international borders, transfer pricing is an integral component to your tax compliance, planning and risk management. Complicating the situation is that over 40 countries have different rules and regulations in place that all require specific documentation.

The professionals at MarksNelson, along with international experts from LEA, will help you with:

U.S. and certain foreign transfer pricing compliance documentation
Pricing planning and risk assessment
Tax controversy services including assistance with the Competent Authority process for double tax relief with treaty countries
Review of transactions for risk assessment
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