-Interest Charge – Domestic International Sales Corporations (IC-DISC)
-Foreign Account Tax Compliance Act (FATCA)
-Review tax efficient holding company jurisdictions and beneficial income tax treaties
-Foreign tax credit management and optimization
-Manage effectively connected income (ECI) and permanent establishment (PE) risks
-Tax efficient financing and capitalization, understanding commercial debt/equity constraints and the cash needs of treasury
-Foreign exchange rate hedging and the associated tax consequences under section 987 and straddle rules under section 1092
-Foreign Bank and Financial Accounts (FBAR)
-Foreign Investment in Real Property Tax Act (FIRPTA)
-Puerto Rico Act 60, Chapters 2 and 3
-U.S. Virgin Islands Economic Development Commission Tax Incentive Programs, including the University of the Virgin Islands Research and Technology Park Tax Incentive Program
Expert tax consulting - not just for businesses
Looking for tax advice regarding private or personal matters? Contact us today! Tax planning for expatriates and persons residing in the U.S. (i.e., tax planning at the individual level) should always be considered, regardless of whether cross-border business is involved.
We build tax models, tailoring tax solutions to your facts
Tax planning is not one-size fits all; for example, entity choice after tax reform for a company generating over $50M a year may not be the same for a small business with minimal foreign-source revenue. Tax modeling can estimate the amount of future tax savings under a particular tax structure, providing clarity before you invest and change operations in order to accommodate a new tax structure.