International Tax | Briggs & Veselka Co.

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

Crystal Gates

Jason Sanders

Brad Gold

International Tax Services