Global Tax Structuring and Business Alignment

Businesses with existing and growing global footprints need to implement and maintain their legal and operational structures. The alignment of legal, operational and tax entities is critical to the success of a global structure. We assist our clients with the evaluation of their existing and growing structures to help improve effectiveness and to mitigate inefficiencies.

Expansion Into New Markets and Territories

As our clients consider expansion into new markets and territories, we work closely with them to anticipate and plan for the challenges that they will face. Working closely with LEA member firms, local law firms and other advisors, we build and collaborate with a tailored team that will work to position our clients for success in a new market.

Cross-border Financing and Cash Flows

Businesses with growing and mature structures face different cash flow management challenges, including:

• Capitalization of overseas businesses
• Repatriation and redeployment of cash
• Local foreign exchange control
• Withholding taxes

We help our clients plan for, and resolve these challenges to lessen constraints on cash flow.

Support for Mergers, Acquisitions, Reorganizations and Other Transactions

Our clients undergo continuous growth and evolution. This often takes the form of acquisitive transactions or other reorganizations. We help our clients:

• Determine tax and other exposures
• Consider tax and business planning opportunities
• Evaluate and implement reorganizations

We stand by our clients throughout these transformative events to help ensure their successful implementation.

Controlled Foreign Corporation ("CFC") Matters (e.g., Subpart F, Earnings & Profits Analysis, etc.)

We advise and consult with our clients regarding the complex areas of U.S. tax law that apply to their foreign structures, including:

• Subpart F
• Earnings and profits
• Foreign tax credits
• Outbound and inbound transfers of assets
• Foreign partnerships

U.S. Foreign Reporting and Tax Compliance

We prepare and review U.S. foreign reporting forms, including:

• Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations
• Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation
• Form 8858, Information Return of U.S. Persons with Respect to Foreign Disregarded Entities
  
• Form 8865, Return of U.S. Persons with Respect to Certain Foreign Partnerships
• Form 8805, Foreign Partner's Information Statement of Section 1446 Withholding Tax
• Form 3520, Annual Return to Report Transactions with Foreign Trusts

In the course of preparing and reviewing foreign reporting forms, we help our clients identify areas of potential risk and opportunity.

Transfer Pricing

A key area of focus by tax authorities around the world, we work with our clients to create and implement transfer pricing policies and create contemporaneous documentation that meets the requirements of the jurisdictions in which they operate.

Export Incentives

Meaningful tax incentives for U.S.-based manufacturers still exist. We work with our manufacturing clients to evaluate their specific facts and circumstances in order to determine whether they may benefit from these incentives. Specifically, your business might benefit from the Interest Charge Domestic International Sales Corporation, or “IC-DISC”. IC-DISC is a mechanism by which certain manufacturers can obtain a significant tax benefit. Despite being subject to a very complex set of rules, if set up properly and appropriately, the IC-DISC can become an important part of a manufacturer’s global structure.