U.S. Investment Overseas

We work with U.S. businesses that have international investment and operations to devise an optimal structure that conforms to business needs and reduces tax exposure. We offer services that include advising on entity selection, investment structuring, taxation of financing and cross-border payments, supply chain planning, foreign tax credit planning, and more. 

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 help you navigate the complex rules, compute the tax benefits, and manage associated tax reporting. 

American companies that generate excess cash overseas have the option of either redeploying their capital or repatriating funds to the United States. 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. Our team minimizes taxes that are applicable in both the United States and foreign countries.

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 United States is subject to complex limitation rules that are 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.

Significant changes to U.S. tax laws in recent years have created challenges for global businesses that seek to take advantage of tax opportunities and maintain 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. Weaver’s professionals work with you to calculate the expected tax impacts of new regulations. We’ll determine a base case as well as modeling scenarios to identify key drivers impacting the global effective tax rate.

For companies that are expanding globally, Weaver offers strategic tax analysis and guidance to maximize available tax attributes that reduce the global effective tax rate. Our team will look at the determination of tax basis, earnings, profits and foreign tax credits. Our tax basis study can be helpful to companies that are evaluating the expected recognized gain or loss when considering selling, disposing or writing off a subsidiary. For companies that are contemplating paying a distribution to shareholders, our earnings and profits analysis determines whether a distribution may be a taxable dividend. 

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 returns, withholding and informational reporting returns, schedules, and statements. Our team works efficiently to help you avoid or minimize IRS penalties, interest, and tax authority audit exposure.