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