As your business expands across borders, its tax structure immediately becomes more complex.

Our international tax team helps design and implement efficient tax structures across borders to ensure your tax position is advantageous - no matter where you do business.

With a team fluent in over 20 languages and access to over 700 accounting advisory firms in 158 countries, Briggs & Veselka provides international tax resources that few other firms can.

Foreign Tax Compliance

Corporate/BusinessIndividualsComprehensive Tax Advice

Corporate/Business

  • Preparation of all U.S. international forms, including Form 1118, 5471, 8865, and 8858
  • Withholding implications on outbound U.S. source income, including FATCA compliance (W-8 series and EIN/ITIN applications)
  • Withholding reporting for foreign partners of U.S. direct investments
  • Foreign tax credit calculations, accruals and carrybacks
  • Entity classification elections – disregarded entity (DRE) or choice type of entities
  • Treaty based tax return compliance

Individuals

  • Non-resident U.S. tax compliance (Form 1040NR)
  • Foreign trusts and passive foreign investment reporting (Forms 3520 and PFIC's)
  • Expatriate tax returns – analysis of tax equalization agreements for foreign assignments
  • IRS Offshore Voluntary Disclosure Program (OVDP) compliance - streamlined and full disclosure programs
  • Foreign bank account and specified foreign assets compliance
  • Tax compliance for relinquishing U.S. citizenship and U.S. permanent resident

Comprehensive Tax Advice

  • Foreign and U.S. tax planning and reporting integration
  • Global tax and consulting outsourcing with affiliated service providers in other jurisdictions
  • CFO and internal accounting staff support
  • Other integrated business advisory services

International Tax Planning

  • Design and implementation of global tax efficient structures
  • Cross-border financing strategies and foreign exchange issues
  • Global tax minimization plans
  • ASC 740-10/FIN 48 analysis (uncertain tax positions)
  • ASC 740/FAS 109 services (accounting and reporting requirements)
  • Foreign tax credit planning, FTC utilization, and Subpart F planning
  • Earnings and profits (E&P) studies
  • Export sales consulting – IC-DISC
  • Transfer pricing consultation on documentation, policies, and agreements
  • Outbound tax considerations of global expansion- including cross-border cash planning, profit/dividend repatriation, funding and capitalization, and foreign currency issues
  • Tax planning for intangible properties and IP migration
  • Inbound tax considerations for entering U.S. markets with efficient tax structures – permanent establishment analysis
  • Inbound tax considerations for foreign nationals on U.S. assignments
  • Cross-border tax treaty analysis and planning for companies and individuals
  • Pre-immigration tax planning for individuals: trust, estates, inheritance, and gift tax planning with cross-border considerations
  • Relinquishing of U.S. citizenship and U.S. permanent resident
  • Universal Tax: Intersection of U.S. foreign tax planning & compliance

Our International Tax Experts

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