International Corporate Tax Services
Many foreign companies and/or their Accounting Firms call on Freed Maxick to provide U.S. tax compliance services. Conversely, Freed Maxick helps U.S. companies and CPA firms across the U.S. navigate through their international tax issues. Even though we are based in Buffalo, NY, companies and individuals from all over the U.S. and the world work with us because of our reputation and experience with international business and tax issues. As a Top 100 Largest CPA Firm in the U.S., we have depth and specialization to handle your U.S. / Global tax issues, no matter how big or how small.
International Tax Structuring
Globalization provides excellent opportunities for growth. Our international tax professionals have positioned numerous organizations to take advantage of the U.S. and/or foreign tax benefits available. We provide insight to suggested strategies, as well as help to formulate your new entity and make required tax elections.
Our process begins by gaining an understanding of your organization and mission. Freed Maxick’s professionals make certain the organization you set up abroad fits within your U.S. structure. We help you select appropriate entity structure, taking into account interplay of U.S.-based tax rules with the tax rules applicable to foreign investors in their country of residence or other potentially applicable locations.
Whether you’re looking at a start-up or acquisition, our team can help determine the best financing structure.
For many start-ups, it takes several years before the entity is profitable. Our professionals will analyze the likelihood of profitability and develop a plan to minimize the financial impact.
Even if you are not considering an expansion, we can help spot opportunities in your existing structures. We’ll thoroughly review your entire organization to spot opportunities to minimize your global tax position.
International Tax Compliance
International tax compliance can be a full-time job, as each country has a host of specialized rules and regulations. Freed Maxick can help companies all over the US to meet their global compliance requirements by assigning the proper tax professional to the related jurisdiction. Each country has its own specialized rules and regulations. We assign a qualified tax professional with experience relevant to their business to help ensure efficiency and accuracy. We offer timely, high-quality responses to the complex tax return and information reporting requirements of international business and investment activity – so you can avoid significant penalties for noncompliance and maintain the most tax-favored position. There are three additional reasons to seek timely, accurate compliance services:
- Examining the risks and challenges presented by foreign and domestic tax laws can minimize cross-border disputes
- First-hand knowledge of foreign tax structures can lessen the risk of double taxation
- Establishing the appropriate entity can achieve additional tax savings under the IC-DISC regime.
Merger & Acquisition
If you are contemplating an inbound or outbound reorganization, we can help in a number of ways. Our service offerings include helping you assess the mechanics of the deal, applicability of tax-free reorganization laws and Section 338(g) if applicable, purchase accounting as well as Due Diligence consulting.
Global Withholding and Reporting Requirements
As the global tax information and withholding requirements expand, we can assist with various business and individual filings. These include everything from Form W-8 series to FIRPTA and Form 1042 series filings.
Income Tax Treaty Consulting
Our professionals can help you navigate through the complexities of over 50 Income Tax treaties the US has with other countries. This includes consulting on permanent establishments, taxability of business profits, treaty based tax return filings, as well as consulting regarding the applicability of reduced rates of withholding under these treaties.
State and Local Income and Sales Tax Consulting
Our dedicated team of State tax experts are trained to deal with all of your state needs. Whether it’s analyzing the applicability of the sales tax laws, preparing state income and franchise tax returns, or preparing a Nexus study, we can consult with you regarding any state in the US.
Transfer Pricing Consulting
Whether you have intercompany management fee charges, product sales or royalty charges, our team can help with your transfer pricing needs. We can assist in reviewing your current transfer pricing for reasonableness, assist with documentation of intercompany charges through a study, or show you how to use transfer pricing as a tax planning tool.
Interest-Charge Domestic International Sales Corporation (IC-DISC) – Freed Maxick can help qualifying companies implement a permanent 20% tax savings strategy called an IC-DISC. This service offering involves:
- Helping you estimate the potential tax savings
- Walking you through the simple implementation and set up requirements
- Helping you maximize your tax savings by analyzing your qualifying sales
- Preparing the required annual tax filings
Foreign Tax Credit Planning – The professionals at Freed Maxick can help maximize and support a foreign tax credit claim by performing earnings and profits and tax pool studies and reviewing your methodology for sourcing income and allocating and apportioning deductions. We can also help with strategies to utilize your excess foreign tax credits.
Foreign Financing Structures – For companies that are expanding globally, Freed Maxick can assist with the implementation of foreign financing structures to take advantage of international tax treaties and help defer US taxation.
Check-the-Box Regulations – In order to minimize taxation in the US, we can assist with planning and determining the benefits or detriments of applying the Check-the-Box Regulations to your global structure.
Subpart F Income – Due to the complexities of operating overseas and the US Controlled Foreign Corporation rules, many US entities do not avoid the Subpart F traps and therefore have deemed dividends to the US, when those amounts could have been deferred. The tax professionals at Freed Maxick can help review your current structure and operations to determine if you have fallen into these traps, or assist in ways to avoid them for future operations.
These consulting services are delivered globally through the efforts of over 100 tax professionals on the Freed Maxick team, along with thousands of professionals that are part of Freed Maxick’s affiliation in Global Alliances which include international professionals located in over one hundred independently-owned accounting and consulting firms.