For companies and individuals with multinational investments and operations, doing business outside the U.S. comes with unique challenges and significant opportunities. Complying with tax regulations of more than one jurisdiction, maximizing opportunities for tax savings and incentives, managing supply chains and supporting expatriate employees are just a few challenges.
Weaver’s international tax team offers a range of accounting services and support to businesses and individuals to help maximize the benefits of overseas operations and investments. Our global reach includes membership in affiliate networks that give our clients access to a coalition of accounting professionals with knowledge of local regulations based in countries around the world.
Our U.S. investment overseas services include:
Outbound Structure Planning
We work with U.S. businesses that have international investment and operations to devise an optimal structure that conforms to the needs of the business while reducing tax exposure. This may include entity selection, investment structuring advice, advising on the taxation of financing and cross-border payments, supply chain planning, foreign tax credit planning, and other tax planning applicable to US businesses with investment overseas.
If your company has transactions with foreign businesses, you may qualify for a permanent tax savings through a Foreign Derived Intangible Income (FDII) deduction, which is available to certain C corporations on qualifying sales, services or license income earned from foreign persons. Your company may also qualify for the IC-DISC (Interest Charge-Domestic International Sales Corporation) incentive, which significantly lowers tax burdens by allowing a conversion of a portion of profits on sales from the ordinary income tax bracket to a more preferential tax bracket. Our tax professionals can determine whether your company is eligible for either incentive, and if applicable, help you navigate the complex rules, compute the tax benefits and assist with associated tax reporting.
Cash Repatriation Planning
U.S. companies that generate excess cash overseas have the option of either redeploying their capital or repatriating funds to the U.S. Weaver provides clients with cash management strategies and planning opportunities to deploy and repatriate cash efficiently through the use of dividends, royalty payments, management fees, and loans. Additionally, we account and seek to minimize any taxes, such as withholding or income taxes, applicable in both the U.S. and foreign countries.
Foreign Tax Credit Management
To alleviate double taxation, U.S. taxpayers can claim a tax credit for income taxes paid or accrued to foreign countries against their U.S. tax liability. The ability to take a foreign tax credit (FTC) in the U.S. is subject to complex limitation rules significantly modified by the Tax Cuts and Jobs Act of 2017. By evaluating available methods and elections to compute the maximum FTC, our tax professionals can help you increase liquidity by reducing your tax liabilities.
Tax Reform Modeling and Strategic Tax Review
Significant changes to U.S. tax laws in recent years have created challenges for global businesses seeking to take advantage of tax opportunities while maintaining compliance with U.S. and foreign regulations. Changes in one area may have a positive or negative impact on another part of a company’s balance sheet. With their understanding of previous and current U.S. tax laws, Weaver’s professionals work with these businesses to calculate the expected tax impacts on their operations of new regulations. This includes determining a base case as well as modeling scenarios to identify key drivers impacting the global effective tax rate.
As companies expand globally, we also offer strategic tax analysis and guidance to maximize available tax attributes to reduce the global effective tax rate. These may include determination of tax basis, earnings, profits and foreign tax credits. A tax basis study can be helpful to companies that are evaluating the expected recognized gain or loss when contemplating on selling, disposing or writing off a subsidiary. An earnings and profits analysis determines whether a distribution may be a taxable dividend when a company is contemplating paying a distribution to shareholders.
International Tax Compliance
Multinational businesses are subject to complex U.S. tax reporting and computations. Our experienced team understands tax reporting requirements and can prepare your company’s U.S. income, withholding and informational reporting returns, schedules and statements. We do so efficiently and timely to help you avoid or minimize IRS penalties, interest and tax authority audit exposure.
To identify tax compliance errors and tax underpayments, the IRS has increased its focus on multinational business and cross border transactions, as well as on high net worth individuals with international investments. We work with clients to resolve an identified controversy or reduce future risk through IRS controversy representation and resolution, penalty prevention and abatement and pre-filing review of tax returns to evaluate potential risk areas.
Transfer pricing analysis can help prevent multinational businesses from setting prices that result in higher global taxes and ensure that profits from transactions between a U.S. business and its foreign subsidiary/parent are fairly priced (i.e., arm’s length) and taxed reflective of the relative risks and functions of each entity. These transactions can include the purchase or sale of tangible goods, services, and the licensing of technology or intangible assets such as know-how, trademarks, copyrights, and patents. Many countries now have transfer pricing regulations. Weaver can assist businesses with selecting intercompany pricing that meets commercial needs and conforms to both U.S. and foreign transfer pricing requirements by leveraging our foreign affiliate network.
Our team works across a myriad of industries to provide U.S. investment overseas services in: