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International Tax
International Tax
Optimizing your competitive edge in a global marketplace
Overview
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:
- Understanding and dealing with developments in technology and e-commerce, and how these developments impact worldwide tax laws;
- Developing techniques for timing the repatriation of profits to the U.S.;
- Launching operations in the U.S., if you are a foreign business seeking entry in the U.S. marketplace;
- Advising you on how to compete in the global marketplace in light of the complexities of the U.S. tax code;
- Optimizing the use of excess foreign tax credits;
- Using pre-immigration tax planning to ease the burden of U.S. income tax and estate law;
- Avoiding inadvertent U.S. tax residency issues;
- Understanding and dealing with the U.S. anti-deferral income tax regime.
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.
Service Menu
Friedman’s international tax team offers a host of services to help you reduce exposure and minimize tax. They include:
- Inbound and outbound transactions, including acquisitions and dispositions
- Offshore holding and operating structures
- Planning and structuring
- Intellectual property structuring
- Cross-border finance
- Foreign investment in U.S. real property
- Voluntary disclosure compliance
- Tax treaty analysis and consulting
- Techniques and timing of repatriation of profits to the U.S.
- Optimization of excess foreign tax credits
- Advice on navigating the U.S. anti-deferral income tax regime
- Transfer pricing studies and documentation, including benchmarking and comprehensive studies
- Tax consulting on entry into the U.S. marketplace by a foreign business, including whether to operate as a branch or subsidiary
- International tax reporting and compliance
- Tax consulting on classification of entities to optimize a multinational’s worldwide tax position
- Consulting to avoid inadvertent residency issues
- Pre-immigration tax planning to ease the burden of U.S. income tax and estate tax
Client Success
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.
Insights & Events
- April 13, 2021 The Made in America Tax Plan (so far)
President Biden campaigned on a promise to “Build Back Better.” He also promised to raise corporate taxes, eliminate tax breaks...
Read more - August 3, 2020 Ryan Dudley in an Exclusive Interview with the Financial Advisor: How Clients with International Holdings Can Benefit From New Tax Regs
Friedman’s Ryan Dudley, International Tax Practice Co-Leader, spoke in an exclusive interview with the Financial Advisor on how clients with...
Read more - June 3, 2020 Hong Kong COVID-19 Subsidy for Employers to Fund Wages of Employees
On May 18, 2020, the Hong Kong Government announced an updated version of the implementation plan for the Employment Support...
Read more - May 1, 2020 When Asset Values Fall, Tax Opportunities Arise
[This article was updated on April 29 to reflect the IRS’ §7520 for May 2020] While it is worrisome to watch...
Read more
- April 13, 2021 The Made in America Tax Plan (so far)
President Biden campaigned on a promise to “Build Back Better.” He also promised to raise corporate taxes, eliminate tax breaks...
Read more - August 3, 2020 Ryan Dudley in an Exclusive Interview with the Financial Advisor: How Clients with International Holdings Can Benefit From New Tax Regs
Friedman’s Ryan Dudley, International Tax Practice Co-Leader, spoke in an exclusive interview with the Financial Advisor on how clients with...
Read more - June 3, 2020 Hong Kong COVID-19 Subsidy for Employers to Fund Wages of Employees
On May 18, 2020, the Hong Kong Government announced an updated version of the implementation plan for the Employment Support...
Read more - May 1, 2020 When Asset Values Fall, Tax Opportunities Arise
[This article was updated on April 29 to reflect the IRS’ §7520 for May 2020] While it is worrisome to watch...
Read more - January 1, 2020 2019-2020 Tax Guide
The elimination of familiar tax planning strategies under the Tax Cuts & Jobs Act (TCJA) in addition to potential changes...
Read more - December 20, 2019 Ryan Dudley on Corporate Effective Tax Rates
Co-Practice Leader of Friedman's International Tax Group, Ryan Dudley, recently shared insight with Fortune.com on effective tax rates and how...
Read more - September 16, 2019 How Uber Could Save Billions
Co-Practice Leader of Friedman's International Tax Group, Ryan Dudley, recently sat with Fortune to discuss the possibly massive effects a...
Read more - July 31, 2019 New IRS Enforcement Programs
Two recently announced IRS compliance campaigns targeting foreign bank account reporting could lead the IRS to discover more noncompliant U.S....
Read more - July 29, 2019 TCJA-Altered Landscape Keeping Firms from Relocating
The recent corporate tax rate drop to 21 percent may be causing U.S. based companies to think twice before relocating...
Read more - June 27, 2019 Large Corporations Aren't Moving Back to the U.S. Just Yet
Allergan Plc, a drug company that moved to Ireland in 2015 to avoid U.S. taxes, has been acquired by AbbVie Inc. signaling...
Read more - June 14, 2019 International Tax Alert: Withholding Tax on Sales of Partnership Interests by Foreign Person(s)
The Tax Cuts and Jobs Act (“TCJA”) imposed tax on gains derived from the disposition of interests in partnerships carrying...
Read more - February 4, 2019 Ryan Dudley on 'Arm's-Length' Tax Policy in the OECD
Friedman's International Tax Practice Leader, Ryan Dudley, provided Law360 with exclusive insights and knowledge on the possible changes to the...
Read more - December 11, 2018 Tax Structuring and Planning Considerations for International Businesses
With 2019 around the corner, international businesses still have an opportunity to restructure ownership and operations to exploit the dramatic changes...
Read more - November 13, 2018 Tax Guide 2018-2019
Concerned how the latest tax developments may impact your 2018 tax strategies? As you head into your 2018 tax planning, this...
Read more - October 23, 2018 Ryan Dudley Featured in Law360
Ryan Dudley, Practice Leader of Friedman's International Tax Group, was asked for insight on how efforts to combat international tax...
Read more - August 13, 2018 [Video Series] Unraveling Tax Reform -- FDII
Learn if your domestic C corporation can reap the benefits of a lower tax rate with the new deduction for...
Read more - July 30, 2018 [Video Series] Unraveling Tax Reform -- GILTI
Gain an international perspective on tax reform with vital knowledge from Ryan Dudley, CPA, CA, CTA, MIT, Partner and Leader...
Read more - July 9, 2018 [Video Series] Unraveling Tax Reform -- Transition Tax
Watch the third episode in this exclusive series featuring Edward Ajodah, CPA, J.D., Principal for ways to help you identify...
Read more - March 6, 2018 Avoid Costly Consequences with Must-Know Information on the Transition Tax Toll-Charge
Enacted on December 22, 2017 the Tax Cuts and Jobs Act introduced a one-time toll-charge or transition tax on accumulated...
Read more - February 22, 2018 [Video] New Tax Code, New Strategies Seminar
Gain the knowledge you need to reap tax benefits and avoid pitfalls in the wake of the most significant overhaul to...
Read more - February 6, 2018 Ryan Dudley Featured in FDI Intelligence, “Multinationals await implementation of global tax realignment.”
Uncertainly 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 more - February 6, 2018 Ryan Dudley Shares Insights in Law360’s, “EU Nations Won’t Wait For Agreement On Digital Tax Rules.”
The US and EU are on different wavelengths when it comes to an agreement on digital tax rules. Dudley says,...
Read more - January 19, 2018 GILTI Tax Casts Broad Fishing Net
The New International Tax Law created a new type of tax on global intangible low-taxed income (“GILTI”) that has a...
Read more - December 22, 2017 2017 Tax Reform: International Tax Provisions in the Conference Report
As 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 more - November 9, 2017 House Tax Reform Bill: Digging Below the Surface to Reveal Critical Analysis
By now, you’ve seen media headlines covering the House Tax Reform Bill introduced on November 2. What you may not...
Read more - November 6, 2017 Download Tax Reform White Paper Now!
As Washington takes up the mantle of tax reform, Friedman LLP proudly releases a timely study featuring insights gleaned from a...
Read more - October 5, 2017 Breaking News: Ominto, Inc. Appoints Friedman as New Audit Firm
We are pleased to announce that Ominto, Inc. has appointed Friedman LLP as its new audit firm. Ominto is a...
Read more - October 3, 2017 Highlighting the Unspoken in the September Tax Reform Framework
This exclusive Tax Alert provides expert insights on critical areas not mentioned in the President's recently released tax reform framework....
Read more - September 28, 2017 White House Tax Reform Framework Released
The White House released its promised tax reform agenda, known as the “September Framework.” While longer than the previous version,...
Read more - June 8, 2017 Webinar Recording | Tax Reform in the Trump Era
Concerned how tax proposals may impact you and your business? Learn how other business leaders would react to tax reform...
Read more - May 12, 2017 Survey Says: Mixed Reaction to International Tax Reforms, Impact Remains Uncertain
As President Trump and Congress tackle comprehensive tax reform, one of the most critical and controversial challenges is to effectively...
Read more - April 1, 2017 Special Tax Reform Series
As Washington takes up the mantle of tax reform, Friedman LLP proudly releases a timely series of insights gleaned from...
Read more - July 7, 2016 Global Commerce 101: A Primer on the Int’l Tax Issues
The opportunities for small and midsized businesses to sell overseas comes with a number of pitfalls as well as benefits....
Read more - July 6, 2016 Ambiguities in IRS Country-By-Country Rules May Cause Woes
The IRS’ final regulations requiring multinational corporations to report financial data for all jurisdictions they operate in was the topic...
Read more - June 9, 2016 5 Tips for Complying with Country-by-Country Tax Reporting
Why are the newly mandated country-by-country tax reporting mechanisms raising “how-to” questions for business leaders? Ryan Dudley, partner for the...
Read more - November 4, 2015 Tax Alert: Rapidly Rising Risks for Offshore Bank Accounts
Time is running out for US citizens and US residents who have offshore bank and financial accounts and have not...
Read more - October 1, 2015 Are corporate tax inversions 'unpatriotic'?
Moving overseas to cut the tax burden remains a viable option for some firms, though the presidential candidates may have...
Read more - July 1, 2015 BEPS implementation in the US - Now comes the hard part
Do 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 more - March 24, 2015 Real Estate Transfer Taxes in New York
Real 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 more - November 5, 2014 International estate planning: Handle with care
If 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 more - November 5, 2014 Second Homes In New York May Have Severe Tax Consequences
The 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 more - November 4, 2013 Partner Ryan Dudley Quoted in International Business Times
Partner Ryan Dudley was quoted in an article on the international tax evasion crackdown in International Business Times.
Read more - Tax Tips: May/June 2015
A 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 more
- November 14, 2017 Exclusive Strafford Webinar Event Hosted by Ryan Dudley
On November 14, Friedman Partner Ryan Dudley will host an exclusive webinar titled “Foreign Investment in U.S. Real Property: Tax...
Read more