International Tax Planning |
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International Structuring
As you expand globally, you need advice on planning your foreign operations to minimize tax costs. Our forward–thinking approach can help you achieve your international tax planning goals.
Our professionals are well known for delivering innovative international tax planning advice and solutions by helping you:
- Plan cross border structures, taking into account the unique issues of C corporations, S corporations, partnerships and limited liability companies
- Assess the unique tax issues facing foreign–owned businesses operating in the U.S.
Inbound Tax Planning
We advise foreign companies on U.S. income tax exposure, focusing on:
- Inbound structuring
- The branch profits tax
- Withholding tax
- Conduit financing
- Earnings stripping
- Tax treaty implications
Foreign Repatriation Planning
Count on Clifton Gunderson to assist you in choosing the right jurisdiction to maximize the use of foreign earnings at a minimum global tax cost.
Our professionals work closely with you to design cash management strategies that integrate with your business strategies. With this focus, you can minimize the tax costs of repatriating foreign earnings or reinvesting them abroad.
Foreign Earnings and Profits (E&P)
Maintaining accurate foreign earnings and profits (E&P), and related tax pools, is essential in determining the effective tax rate of a foreign subsidiary, and in preparing accurate tax returns and financial statements. Both the Internal Revenue Service and the Securities Exchange Commission have increased their attention in this area in recent years.
A number of foreign tax issues depend on E&P including:
- Foreign tax credit utilization
- Deemed paid foreign tax credits
- Subpart F inclusions
- Effective tax rate for financial statements
Our professionals have the experience, knowledge of processes and software tools to assist you with:
- Determining and maintaining accurate E&P and tax pools
- Working with foreign affiliates to gather information
- Analyzing E&P accounting methods and related tax elections
- Modeling alternative E&P repatriation scenarios
FIN 48
Financial Accounting Standards Board (FASB) Interpretation No. 48 (FIN 48) requires that all uncertain tax positions be quantified. Our engagement teams can use proprietary software to model global tax positions for financial statement purposes.
The tax impact of international operations is often the largest driver in achieving a global effective tax rate that is significantly different than the U.S. statutory rate. Major rate drivers we consider are:
- Foreign tax rates that are substantially different than U.S. rates
- Interplay of the U.S. worldwide tax regime and complex foreign tax credit utilization rules
- FAS109 deferred income tax recognition principles and the potential applicability of the indefinite reversal criterion of APB23
- Subpart F income
- Related party transactions subject to transfer pricing adjustments
- Permanent differences relating to export tax incentives, R&D credits and the domestic production activity deduction
- Impact of foreign currency translation rates
