The Internal Revenue Code has complicated rules regarding the reporting of foreign items, with significant penalties for failure to report, or incomplete reporting. We can help you with U.S. tax preparation and planning for both inbound and outbound transactions, in order to minimize global taxes and reduce penalty exposure.

Many foreign entities and investments do not fit neatly into our U.S. classifications, or have special reporting requirements (such as foreign mutual funds). We can help you with analysis of your foreign entity, determine required reporting obligations, and assist you with the entity selection process, when a choice is available.

We also assist both businesses and individuals with treaty analysis, such as tax exclusions, and tax residency and/or permanent establishment analysis.

Our individual tax preparation services include foreign bank account reporting forms, foreign financial asset reporting, foreign mutual fund (PFIC) reporting, foreign trusts (grantor and non-grantor), foreign gifts and foreign estates, and non-resident income tax returns.

Our business tax preparation services include U.S. parent companies with foreign subsidiaries (controlled foreign corporations, foreign disregarded entities, foreign partnerships and foreign branches); U.S. branches or subsidiaries of foreign parent companies; and withholding and FATCA reporting requirements.

Offshore Voluntary Disclosure Services (OVDP or OVDI)

Although we always prefer to assist clients before they have foreign reporting issues, we have worked extensively with Offshore Voluntary Disclosures, since the first iteration of the program in 2009. We work closely with attorneys to provide consultation for taxpayers considering entry into the Offshore Voluntary Disclosure Program, or a Streamlined Program, so that taxpayers may make an informed decision as to their risks and penalty exposure.

We follow the IRS’s recommendation that a tax attorney be engaged in all Offshore Voluntary Disclosure cases. Our services include amended return and Foreign Bank Account Reporting (FBAR) preparation, as well as penalty and interest calculation. All documentation required for the program will be provided to your attorney for filing with the IRS.

Transfer Pricing Services

Gone are the days when transfer pricing applied only to large corporations.  Today transfer pricing is important for all multi-national entities in order to reduce audit risk, reduce your effective global tax rate, and monetize foreign tax credits. We work with small and mid-size multi-national firms to analyze your cross border transactions and determine your transfer pricing needs.  We then work with you to determine the appropriate method, analyze comparables, and ascertain the appropriate level of documentation for your business.  We will also assist you to finalize and implement appropriate internal policies to administer your transfer pricing structure.