Our team comprises of motivated specialized senior tax professionals with knowledge and expertise in International Tax issues thereby contributing quality tax planning to our clients. We can advise on all aspects of international tax from cross-border transactions to mergers and acquisitions and global transfer pricing.
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| Our professionals have the technical knowledge and realistic experience helping organizations seize tax opportunities. |
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| International Tax issues that we cover in our services, include: |
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US and Foreign persons for Tax purposes
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| Resident and Non-resident aliens - Green Card test and Substantial presence test |
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| US persons - Foreign Tax credit & Foreign earned income exclusion |
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| Foreign persons with US income |
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| US and Foreign corporations |
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| Foreign corporations with US owners - Foreign personal holding companies (FPHC), Controlled foreign corporations (CFC), etc. |
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| Nonbusiness Income From U.S. Sources - Interest, Dividends, Rents, Royalties, Capital gains |
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| Withholding of Taxes at Source |
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| Payments to Partnerships, Trusts, and Estates |
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| Nonbusiness Income From U.S. Sources |
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| Income Effectively Connected With U.S. Business |
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| Permanent establishment (PE) in US and Income attributable to a permanent establishment |
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| Personal services performed in the United States |
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| Treaty shopping rules |
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| Gains on Dispositions of U.S. Real Property Interests |
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| USRP (US Real Property) Interests and USRP Interests Held Through Partnerships, Trusts, and Estates |
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| Branch Profits Tax and Branch-Level Interest Tax |
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| Controlled Foreign Corporation (CFC) |
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| Foreign Personal Holding Company Income - Dividends, Interest, and Annuities, Rents and Royalties, ains on Sales of Investment Property, etc |
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| Foreign Base Company Sales and Services Income |
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| Earnings Invested in U.S. Property; Earnings Invested in Excess Passive Assets |
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| Taxation of Subpart F Income and Earnings Invested in U.S. Property and Excess Passive Assets |
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| Passive Foreign Investment Companies (PFIC), Foreign Personal Holding Companies and Foreign Investment Companies |
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| US Income Tax treaties |
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| Transfer Pricing issues - Section 482 Reallocations |
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| Corporate (including historic) income tax rates |
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| Indirect tax rates |
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| Domestic and treaty withholding tax rates |
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| Comparative data on holding companies and transfer pricing policies |
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| Foreign tax credit tax advice and manage global structural tax rate |
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| Cross-border structured finance tax advice |
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| Compliance and planning assistance in relation to international trade and customs issues |
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| Provide tax efficient structuring of cross-border mergers, de-mergers, acquisitions, spin-offs, and joint venture arrangements |
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| Implement tax planning for financing and investment structures, including off-balance financing, domestic and cross border asset leases, and other asset-based structured transactions and financial products
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| Transfer pricing planning, documentation, and audit assistance |
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