International tax overview

INTERNATIONAL TAX SERVICES

International trade is a key element of the business strategy for many of our clients.  At Noell Agnew & Morse, we combine our knowledge of your business and its industry, with our experience serving companies similar to yours, to help you craft a business strategy to maximize the results from your international operations.  We can draw upon our extensive multi-national knowledge and experience in prior transactions to help you structure your operations to meet your business needs, while minimizing your total tax obligations.  Through our affiliation with RSM International, we have access to tax and accounting professionals in more than 75 countries.  We have the expertise and resources to assess your needs and respond with solutions that are relevant, practical, cost-effective and easy to implement.  Following are some of the key areas where we can work with you to maximize your opportunities for international business success:

• Export incentive planning - there are significant tax benefits available to U.S. companies who are engaged in the export of goods to foreign countries.  One of the key vehicles available is the use of an IC-DISC (Interest Charge-Domestic International Sales Corporation).  For more information on how an IC-DISC could provide significant benefit to your business operations, please see our detailed example here.
• Formation of foreign entities - the establishment of foreign operations generally necessitates a detailed review of your domestic and foreign operations as they exist now, as well as contemplated future growth, to ensure that your business structure is optimized to meet your business needs, while minimizing your foreign and U.S. tax obligations.  The proper structure will not only provide you the flexibility you need for business success, it will allow you to take full advantage of the benefits available under the tax law of the countries in which you operate.  For more information on the issues to consider in establishing foreign operations, please see our whitepaper on foreign entity structure planning.
• Transfer pricing - with the increased emphasis on transfer pricing regulations, companies face an increasing risk of audit by the IRS and foreign tax authorities.  We can review your inter-company transactions to ensure that you are complying with the appropriate transfer pricing regulations.
• Tax compliance - establishment of foreign operations generally requires expanded reporting requirements, both domestically and in the foreign countries in which you operate.  Through our affiliation with RSM International, we can access the resources of skilled professionals to assist in this effort, no matter where your operations are located.
• Foreign tax credit planning and reporting requirements - establishing operations in a foreign country will result in some portion of your business income being subject to tax in that foreign jurisdiction,  The specifics of this will vary based on the entity structure employed, as well as the terms of tax treaty between the U.S. and the foreign jurisdiction.  We will work with you to ensure that your entity structure is optimized and that your operations are structured to maximize the use of any foreign tax credits and minimize your overall tax obligation.
• Foreign bank account report compliance (FBAR) - while FBAR reporting requirements have been in place for many years, significant expansions in required reporting and associated penalties for non-compliance have garnered the attention of many taxpayers.  We can work with you to understand the extent of your required reporting requirements and assist in the establishment of an annual reporting system for these required filings. 
• Expatriate planning & compliance - employment of U.S. citizens in foreign operations can result in many tax planning opportunities – for you and your employees. Employment of foreign nationals in domestic operations offers similar planning issues.  We can work with you to ensure that your international employees pay the minimum amount of tax necessary.