By David M. Desmarais
By Daniel M. Andrea
By Moshe Golden
By Christopher Parnagian
Global Tax Structuring and Business Alignment.
through the our connection with the Leading Edge Alliance (LEA)
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.
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.
Businesses with growing and mature structures face different cash flow management challenges, including:
We help our clients plan for, and resolve these challenges to lessen constraints on cash flow.
Our clients undergo continuous growth and evolution. This often takes the form of acquisitive transactions or other reorganizations. We help our clients:
We advise and consult with our clients regarding the complex areas of U.S. tax law that apply to their foreign structures, including:
We prepare and review U.S. foreign reporting forms, including:
In the course of preparing and reviewing foreign reporting forms, we help our clients identify areas of potential risk and opportunity.
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.
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.
Linda Mui, CPA
John D. Trejo, CPA