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For foreign businesses seeking entry to the U.S. and U.S. businesses competing in a global marketplace, navigating the complexities of international tax rules can be daunting. To capture tax savings opportunities and maximize your position in a shifting landscape, rely upon the deep knowledge of Friedman’s International Tax Services team.
We devise practical strategies to overcome your international tax challenges and communicate solutions to you in a clear and understandable manner. The upshot for you – less exposure, a reduced tax burden, and the potential to reap tax advantages.
Our expertise comes from decades of hands-on experience, advanced degrees and certifications in all areas of taxation, and our membership in DFK International, a worldwide network of independent accounting firms. We work seamlessly with DFK members around the globe to deliver “boots on the ground service” when and where you need it.
Over the years, we have delivered international tax and consulting services for U.S. and foreign businesses as well as for individuals with cross border needs. We can assist you with these and other issues:
Conducting business in the global marketplace is no simple matter. To discuss your international tax needs, contact us or a member of the international tax services team.
Friedman’s international tax team offers a host of services to help you reduce exposure and minimize tax. They include:
Case Study: The Right International Structure Maximizes Tax Savings and Income Growth
The Challenge
A foreign corporation wanted to establish a sales and distribution business for goods it would manufacture in Asia.
The Solution
We developed a structure including: (i) establishing a new offshore corporation in a low tax jurisdiction to buy from the manufacturer and sell to the United States and retain a margin that would be lightly taxed; (ii) establishing a new U.S. corporation to act as the low-risk distributor and helped put in place agreements with the offshore corporation to ensure the U.S. corporation did not create any intangible assets or do anything that would attract excessive U.S. taxation; (iii) prepared a transfer pricing study to justify the pricing between the offshore corporation and the U.S. corporation.
Outcome
This structure allowed the client to derive significant amounts of income in a low tax jurisdiction and reduced amounts of income in the United States, resulting in substantial tax savings.
Friedman’s Ryan Dudley, International Tax Practice Co-Leader, spoke in an exclusive interview with the Financial Advisor on how clients with...
Read moreOn May 18, 2020, the Hong Kong Government announced an updated version of the implementation plan for the Employment Support...
Read more[This article was updated on April 29 to reflect the IRS’ §7520 for May 2020] While it is worrisome to watch...
Read moreThe elimination of familiar tax planning strategies under the Tax Cuts & Jobs Act (TCJA) in addition to potential changes...
Read moreFriedman’s Ryan Dudley, International Tax Practice Co-Leader, spoke in an exclusive interview with the Financial Advisor on how clients with...
Read moreOn May 18, 2020, the Hong Kong Government announced an updated version of the implementation plan for the Employment Support...
Read more[This article was updated on April 29 to reflect the IRS’ §7520 for May 2020] While it is worrisome to watch...
Read moreThe elimination of familiar tax planning strategies under the Tax Cuts & Jobs Act (TCJA) in addition to potential changes...
Read moreCo-Practice Leader of Friedman's International Tax Group, Ryan Dudley, recently shared insight with Fortune.com on effective tax rates and how...
Read moreCo-Practice Leader of Friedman's International Tax Group, Ryan Dudley, recently sat with Fortune to discuss the possibly massive effects a...
Read moreTwo recently announced IRS compliance campaigns targeting foreign bank account reporting could lead the IRS to discover more noncompliant U.S....
Read moreThe recent corporate tax rate drop to 21 percent may be causing U.S. based companies to think twice before relocating...
Read moreAllergan Plc, a drug company that moved to Ireland in 2015 to avoid U.S. taxes, has been acquired by AbbVie Inc. signaling...
Read moreThe Tax Cuts and Jobs Act (“TCJA”) imposed tax on gains derived from the disposition of interests in partnerships carrying...
Read moreFriedman's International Tax Practice Leader, Ryan Dudley, provided Law360 with exclusive insights and knowledge on the possible changes to the...
Read moreWith 2019 around the corner, international businesses still have an opportunity to restructure ownership and operations to exploit the dramatic changes...
Read moreConcerned how the latest tax developments may impact your 2018 tax strategies? As you head into your 2018 tax planning, this...
Read moreRyan Dudley, Practice Leader of Friedman's International Tax Group, was asked for insight on how efforts to combat international tax...
Read moreLearn if your domestic C corporation can reap the benefits of a lower tax rate with the new deduction for...
Read moreGain an international perspective on tax reform with vital knowledge from Ryan Dudley, CPA, CA, CTA, MIT, Partner and Leader...
Read moreWatch the third episode in this exclusive series featuring Edward Ajodah, CPA, J.D., Principal for ways to help you identify...
Read moreEnacted on December 22, 2017 the Tax Cuts and Jobs Act introduced a one-time toll-charge or transition tax on accumulated...
Read moreGain the knowledge you need to reap tax benefits and avoid pitfalls in the wake of the most significant overhaul to...
Read moreUncertainly looms surrounding the imminent implementation of global tax realignment. While multinationals know about country-by-country (CbC) reporting, Dudley shares, "What they don’t know...
Read moreThe US and EU are on different wavelengths when it comes to an agreement on digital tax rules. Dudley says,...
Read moreThe New International Tax Law created a new type of tax on global intangible low-taxed income (“GILTI”) that has a...
Read moreAs a follow up to our December 20 Tax Alert covering domestic tax provisions included in the Conference Report, this alert provides a comprehensive overview of the Report’s international tax provisions. Read on for highlights on the ways you and your business may be directly impacted.
Read moreBy now, you’ve seen media headlines covering the House Tax Reform Bill introduced on November 2. What you may not...
Read moreAs Washington takes up the mantle of tax reform, Friedman LLP proudly releases a timely study featuring insights gleaned from a...
Read moreWe are pleased to announce that Ominto, Inc. has appointed Friedman LLP as its new audit firm. Ominto is a...
Read moreThis exclusive Tax Alert provides expert insights on critical areas not mentioned in the President's recently released tax reform framework....
Read moreThe White House released its promised tax reform agenda, known as the “September Framework.” While longer than the previous version,...
Read moreConcerned how tax proposals may impact you and your business? Learn how other business leaders would react to tax reform...
Read moreAs President Trump and Congress tackle comprehensive tax reform, one of the most critical and controversial challenges is to effectively...
Read moreAs Washington takes up the mantle of tax reform, Friedman LLP proudly releases a timely series of insights gleaned from...
Read moreThe opportunities for small and midsized businesses to sell overseas comes with a number of pitfalls as well as benefits....
Read moreThe IRS’ final regulations requiring multinational corporations to report financial data for all jurisdictions they operate in was the topic...
Read moreWhy are the newly mandated country-by-country tax reporting mechanisms raising “how-to” questions for business leaders? Ryan Dudley, partner for the...
Read moreTime is running out for US citizens and US residents who have offshore bank and financial accounts and have not...
Read moreMoving overseas to cut the tax burden remains a viable option for some firms, though the presidential candidates may have...
Read moreDo the hard yards still lie ahead for the OECD base erosion and profit shifting (BEPS) project?
BEPS implementation relies on engagement from key jurisdictions, including the US; but when it comes to getting key jurisdictions on board, it may be harder than expected. Friedman LLP partner, Ryan Dudley, wrote an article on the topic that was featured in the International Tax Review.
Read moreReal estate transfer tax is a tax imposed by states, counties and municipalities for the privilege of transferring real property within a jurisdiction. The tax is sometimes referred to as real estate conveyance tax, mortgage transfer tax or documentary stamp tax, among other terms.
Read moreIf you or your spouse is a non-U.S. citizen, different rules apply to your estate plan. One misstep can lead to unpleasant tax surprises, so make sure you understand the differences.
Read moreThe New York State and New York City tax laws have numerous traps for unwary nonresidents. To avoid one of the biggest tax hazards, nonresidents owning or renting homes within New York must be aware of the applicable residency tests and what records they should maintain to avoid a dual residency determination. Nonresidents of New York State are only taxed on income earned in or sourced to the state. New York City only taxes city residents. However, if a nonresident is not attentive to the residency tests, the tax consequences can have New York State, and possibly New York City, seeking to impose tax on all income, including interest, dividends, and capital gains, regardless of its source.
Read morePartner Ryan Dudley was quoted in an article on the international tax evasion crackdown in International Business Times.
Read moreA good tax-planning technique is to sell a poor-performing security to “harvest” the loss and offset it against your capital gains. But what if you have high hopes for the security and would like to keep it in your portfolio?
Read moreOn November 14, Friedman Partner Ryan Dudley will host an exclusive webinar titled “Foreign Investment in U.S. Real Property: Tax...
Read more