The landscape of international tax is increasingly complex and dynamic. As competition intensifies, emerging companies are forced to enter into cross-border transactions at an increasing pace. Many of the greatest tax-related planning opportunities for emerging companies can be found within the arena of U.S. international tax. Yet, the U.S. also presents some of the most significant risks. The penalty regime associated with U.S. informational reporting, foreign-owned entities and intercompany transactions is one of the stiffest in the Internal Revenue Code. Furthermore, emerging companies that engage in cross-border activity also subjects emerging companies to various non-U.S. tax regimes.
A&M’s team of international tax experts have deep-experience in designing effective tax strategies for both U.S. and non-U.S. companies with domestic and foreign activities and investments. We specialize in the following areas with respect to emerging markets:
- International Tax Structuring: A&M works closely with our clients to strategize an efficient tax structure that is aligned with their business and operational goals. In our experience, designing and executing an optimal global tax rate is most effective with front-end tax planning and at A&M, we are committed to minimizing the effective rate early-on in the process.
- U.S. International Tax Compliance: Mitigating risk starts with ensuring that all obligations are met for both income tax returns and U.S. informational reporting returns (e.g., FBARs, Form 5472, etc.). Generally, A&M will not only help our emerging market clients understand their information reporting obligations, but also assist such clients with the preparation of returns.
- Global Tax Coordination: A&M’s network of global tax specialists spans the globe through our affiliate Taxand network and other strategic partners. Our highly effective and cohesive network of tax experts provides international support for emerging companies’ consulting and compliance requirements. A&M supports many of our clients as a de facto “outsourced” tax department to make sure that all aspects of global tax compliance are addressed, particularly where our clients are entering new markets at a rapid pace.
- Export Incentive Programs: Under the new Tax Cuts & Jobs Act (and under prior law), the U.S. offers valuable incentives for U.S. exporters. Our team has helped many emerging companies take advantage of IC-DISC structures as well as advising companies on ways to maximize their available benefit under the new Foreign Derived Intangible Income (FDII) rules.