International Tax Services
To effectively navigate the complex international tax laws BlumShapiro offers clients a broad range of international tax services. We help our clients understand and meet their tax compliance obligations. More importantly, we help them identify and reduce their tax risks and implement sound, practical and efficient tax strategies that will meet their needs today and into the future.
Our approach combines strong understanding of our client’s business, economic environment and technical tax knowledge in multiple jurisdictions. We assist multinational organizations engage in tax planning to minimize their overall tax burden.
Inbound and Outbound Tax Planning
We assist our clients with both in-bound and out-bound international tax planning such as choice of entity and structuring, “Subpart F” income analysis, effective tax rate minimization, foreign tax utilization, IC-DISC implementation, transfer pricing planning and documentation, repatriation strategies, withholding tax compliance, tax treaty interpretation and other international tax issues.
Outbound Tax Services
Outbound Tax Planning: Structuring, Anti-Deferral Strategies and Foreign Tax Credit (FTC) Utilization
The U.S. has complicated anti-deferral rules that apply to U.S. owners of controlled foreign corporations (CFCs), passive foreign investment companies (PFICs) and other types of entities that require U.S. owners to include certain types of income (e.g., Subpart F income) of foreign companies in their U.S. taxable income. BlumShapiro can assist with identifying risks associated with these anti-deferral rules, and structuring foreign operations to avoid or minimize current income inclusions. BlumShapiro can also assist in structuring cross-border transactions, operations and optimizing the use of foreign taxes for effective tax-rate planning.
Tax Treaty Planning
BlumShapiro can help companies on structuring and planning transactions and operations to maximize benefits under applicable U.S. tax treaties to minimize overall combined U.S. and foreign taxes.
International M&A and Group Reorganization
A successful merger or acquisition strategy should follow a structured and disciplined approach, with clear strategic objectives, detailed implementation plan, and a focus on creating and capturing value. BlumShapiro will work to support your strategy by assisting with target screening, due diligence, tax structuring, merger integration and post-transaction implementation.
Transfer pricing rules and regulations are becoming increasingly complex and burdensome especially with the advent of the OECD-BEPS project. Examinations are expensive, contentious, disruptive and clearly on the rise in many jurisdictions. In collaboration with BlumShapiro’s worldwide tax affiliates, we can provide a transfer pricing study, document related-party transactions and assist in competent authority relief assistance, including strategic planning for a specific result among treaty partners. We can also assist in preparing a transfer pricing policy that serves as a blue print for related-party transactions.
VAT Advisory & Compliance
Many global corporations have exposure to value added tax (VAT) in many areas of their business, since VAT is the predominant transaction tax outside of the United States. With rates ranging up to 25 percent in various jurisdictions, VAT exposure can grow quickly in the absence of a comprehensive VAT strategy and firm understanding of each jurisdiction’s specific VAT requirements. The following services will be provided in coordination with BlumShapiro’ worldwide affiliates: advisory, refund, controversy and compliance assistance.
Inbound Tax Services
There are many complexities associated with FATCA. It affects both the withholding agents and payment recipients. Compliance with FATCA involves changes to withholding agent’s or the recipient’s financial and tax systems and operations. There could also be potential legal and regulatory implications such as local country privacy and security laws. Full compliance with FATCA means facing heightened requirements.
Withholding Tax Due Diligence
BlumShapiro can perform due diligence services for U.S. corporations and other entities who are withholding agents of U.S.-source income. Our team will work with you to determine withholding and information reporting requirements for U.S. federal income tax purposes. In addition, we will review current accounts payable and other accounting systems and procedures to determine payments requiring withholding under the rules. Our tax experts will then recommend controls and processes to make sure you are in compliance with the Internal Revenue Code.
Outbound/Inbound Tax Compliance
BlumShapiro can provide U.S. international tax information return preparation assistance to companies with operations outside the U.S. In particular, we can assist in the preparation of Forms 5471, 5472, 8858, 8865 and 1118, among others.
We can also provide assistance with the preparation of U.S. reporting of inbound transactions, such as:
- Form 5471 – for foreign owned U.S. corporations,
- Form 1120F – for U.S. federal income tax liability of foreign entities, and
- FIRPTA filings for foreign persons owning U.S. real property interest.
Baker Tilly International
At BlumShapiro, our goal is to provide the answers you need, no matter where your business takes you. That's why we are an independent member of Baker Tilly International, a leading global network of 165 high quality, independent firms that provide accounting, assurance, tax and specialist business advice in 141 countries. The member firms are committed to a common goal of providing the best possible service to their clients, in their own marketplaces around the country and the world. Baker Tilly International is one of the leading networks in the world by fee income.
Navigating these complex international tax laws is very difficult and mistakes and missed planning opportunities can be costly for international businesses. Contact BlumShapiro to learn more about our comprehensive international tax services.