International Tax Services

For many companies, keeping pace in a competitive marketplace means pursuing international growth opportunities. As customers, vendors and partnerships expand across geographies, today’s businesses are becoming more global than ever.

Organizations operating beyond the U.S. borders or considering such expansion require the support only experienced international tax advisors can deliver. Our experts help develop global tax strategies that align optimally with operations as they exist today and with plans for driving future growth.

International tax expertise, anywhere our clients need it.

As the lead North American firm in the PKF International network, PKF O’Connor Davies has access to the expertise of independent accounting firms in more than 400 locations across 150 countries, which means our clients benefit from worldwide representation through a single contact right here at home.

Cross-Border Tax Structuring and M&A

Companies and individuals engaged in cross-border activities often face complex tax considerations due to the overlapping, sometimes competing, tax regimes of different countries. Skillful cross-border tax structuring addresses these challenges and, when possible, helps minimize the overall tax burden through a carefully calibrated assessment of the location of assets, income streams and operations.

Deploying a deep understanding of U.S. federal and international tax law, accounting principles and business operations across jurisdictions, our experienced professionals work with you, your associated legal advisors and financial professionals. They collaborate to develop customized strategies that reflect and promote your specific objectives. Our tax specialists have proficient knowledge of corporate nonrecognition tax provisions, partnership tax rules and judicial doctrines such as step-transaction, business purpose and transitory ownership/existence. When non-U.S. entities or operations are involved, we collaborate with PKF International representatives to develop a tailored plan that incorporates U.S. international tax rules and foreign tax laws to help drive business success.

Not only do our advisors help investors identify U.S. tax risks associated with making a foreign investment, they can also provide local country tax due diligence assistance in more than 150 countries thanks to our active participation in the PKF International network. Count on our specialists for help with the following, which are key cross-border tax structuring techniques:

Transfer Pricing: Establishing prices for transactions between related entities in different tax jurisdictions to allocate profits effectively while complying with transfer pricing regulations.
Tax Treaties: Leveraging bilateral or multilateral tax treaties between countries to avoid double taxation, claim tax credits or benefit from preferential tax rates.
Tax Optimization Strategies: Utilizing tax-efficient structures such as holding companies, intellectual property (IP) licensing and cross-border mergers and acquisitions to minimize tax liabilities.
Entity Selection: Choosing the appropriate legal entity structure for conducting cross-border business activities, considering factors such as tax treatment, liability protection and ease of operation.
Location of Operations and Investments: Establishing subsidiaries, branches or affiliates in jurisdictions with favorable tax regimes or incentives for specific business activities.
Thin Capitalization Rules: Structuring financing arrangements to optimize the mix of equity and debt and to comply with thin capitalization rules that limit the tax deductibility of interest expenses.
Tax-Efficient Repatriation of Profits: Planning the repatriation of profits earned in foreign jurisdictions to minimize withholding taxes, currency conversion costs and other tax implications.

Foreign Account Tax Compliance Act (FATCA)

FATCA is U.S. federal law enacted in 2010 with the primary goal of combating tax evasion by U.S. persons holding assets and financial accounts outside the United States. FATCA requires foreign financial institutions (FFIs) to report information about financial accounts held by U.S. taxpayers or foreign entities in which U.S. taxpayers hold a substantial ownership interest.

Our specialists work with clients to streamline the identification and assembly of data required by the authorities and report that information. This helps avoid or mitigate the significant penalties associated with non-compliance. FATCA reporting involves several key components:

Compliance and Enforcement: FATCA imposes significant penalties on FFIs that fail to comply with reporting requirements, including withholding taxes on certain U.S. source payments. Non-compliant U.S. taxpayers may also face penalties for failure to report foreign financial assets.
FFI Reporting: Foreign Financial Institutions are required to identify and report certain information about financial accounts held by U.S. persons to the U.S. Internal Revenue Service (IRS) or to their local tax authorities, which then shares the information with the IRS.
Form W-8 and W-9: FFIs are required to collect information from their account holders, prepare and file certain documentation. For a non-U.S. person, FFIs must file Form W-8BEN (Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding and Reporting.) To determine the U.S. tax status of a U.S. person, Form W-9 (Request for Taxpayer Identification Number and Certification) is required.
Reciprocal Reporting: The United States has entered into intergovernmental agreements (IGAs) with many foreign jurisdictions to facilitate FATCA implementation. Under these agreements, the U.S. may also exchange information with the respective foreign tax authorities about financial accounts held by foreign individuals and entities in U.S. financial institutions.
U.S. Individual Reporting: As part of their annual tax filing, U.S. individuals and entities with foreign financial assets above certain thresholds are required to report those assets to the IRS on Form 8938 (Statement of Specified Foreign Financial Assets).

Foreign Tax Credit Planning and Utilization

Fundamental to maximizing the benefits from foreign taxes paid is an insightful and multi-faceted analysis of each taxpayer’s specific circumstances. With profound expertise in U.S. tax law, cross-border requirements and regulations, our advisors join forces with our PKF International professionals to ensure that clients comply with and benefit from, proper foreign tax credit planning.

Global Mobility

Today’s evolving, expanding era of remote work and digital nomads offers boundless new opportunity – and nuanced tax complexities. For individuals and companies engaged in international assignments and remote work arrangements, our specialists help ensure compliance with tax laws in both the home country and the country in which the work is taking place. We also identify corporate tax risks, such as permanent establishments, transfer pricing and indirect tax consequences. Our services include:

Coordination with Other Services: We collaborate with legal, Human Resources and relocation services to deliver a comprehensive support package for individuals and companies managing global mobility.
Cross-Border Compensation Planning: We structure tax-efficient compensation packages for expatriates, taking into consideration housing allowances, cost-of-living adjustments, relocation and other expenses.
Employee Education and Support: We help ensure that expatriate employees understand their tax obligations, rights and benefits while working abroad.
Payroll Services: We advise on local payroll issues for expatriate employees, including handling currency conversions, tax withholding and compliance with local labor laws.
Social Security and Pension Plans: We help navigate the complex task of ensuring compliance is handled properly and that tax treaties and equalization benefits are utilized in the most tax efficient way for those working abroad.
Tax Audit Support: We assist with tax audits and inquiries from tax authorities in both the home and host country.
Tax Compliance: We assist with the preparation and filing of tax returns in both the home country and the host country.
Tax Equalization and Protection: We implement tax equalization policies to help ensure that expatriates are neither financially advantaged nor disadvantaged as a result of overseas assignments.
Tax Planning: We design tax efficient strategies for expatriates, including tax equalization, tax treaties and tax credits.

Our global mobility and expatriate tax services play a crucial role in facilitating international assignments and ensuring compliance with tax and regulatory requirements in an increasingly interconnected world.

Indirect Tax-Sales and Use Tax

Businesses and individuals entering the U.S. must handle a range of State and Local Tax (SALT) obligations, which may be characterized by frequently changing regulations, compliance requirements that vary across jurisdictions as well as a complicated array of taxes. With recognized facility in the areas of income, sales, payroll, personal property and gross receipts tax as well as unclaimed property, credits and incentives, we support clients with a complete range of State and Local Tax (SALT) services,

For those leaving the U.S. to operate overseas, our extensive PKF International Network is invaluable in managing the requirements of Value-Added Tax (VAT) and excise duties. Combining highly specific tax expertise and extensive experience, our specialists help ensure that tax issues are handled in a way that reflects a genuine understanding of each client’s unique circumstances.

International Desks

Our international specialists have the expertise and technical knowledge required to offer individuals and businesses comprehensive planning, consulting and compliance services around the globe. With the active participation of experienced senior leaders, our engagement teams combine technical proficiency with genuine understanding of foreign cultures and customs to help promote not just successful ventures but enduring relationships as well.

To navigate directly to information on our Asia Desk, click here.
To navigate directly to information on our EU Desk, click here.
To navigate directly to information on our Latin American Desk, click here.

Offshore Trust Planning

Our expertise in Trust and Estate Planning includes advising on and assisting with, implementation and U.S. tax compliance for trusts outside the U.S. We help clients understand the tax implications of offshore trusts and fully assess the inherent risks and benefits.

While offshore trusts can offer benefits in terms of tax efficiency and asset protection, it’s essential to proceed cautiously and seek professional advice to navigate potential pitfalls and ensure compliance with relevant laws and regulations.

Pre-Immigration Planning and Reporting

When relocating to the United States, planning ahead is crucial. Pre-immigration tax planning and reporting are essential to helping individuals and families manage their tax obligations and optimize their financial situation before making this move. Our team helps address these key considerations before a client’s first day in the U.S.:

Asset Structuring: Advice on the structuring and titling of assets to minimize tax liabilities during and after the relocation, including factors such as capital gains tax, inheritance tax and estate planning.
Cross-Border Wealth Transfer: Guidance on transferring wealth between countries, including gift and inheritance tax implications and structuring trusts or other vehicles for wealth preservation and succession planning.
Expatriation Tax Considerations: Recommendations on any expatriation tax implications, including exit taxes and compliance with expatriation rules.
Foreign Account Reporting: Help avoid penalties by ensuring compliance with foreign account reporting requirements, such as FBAR (Foreign Bank Account Report) and FATCA (Foreign Account Tax Compliance Act.)
Income Tax Planning: Strategy development to manage income tax liabilities, including timing of income recognition, exploring tax-efficient investment options and optimizing the use of deductions and credits.
Retirement Planning: An evaluation of retirement savings and pension plans to ensure they remain tax-efficient in the departing country and are handled properly at distribution.
Real Estate Tax Considerations: An assessment of the tax implications of owning or selling property, including capital gains tax and property tax.
Tax Compliance: Assistance with the preparation and filing of tax returns in the departing country prior to leaving and guidance on ongoing reporting requirements in the U.S.
Tax Residency Determination: An assessment of the individual’s tax residency status in both the departing country and the U.S. to understand any and all tax implications.
Tax Treaty Analysis: A review of the tax treaties between the current residency country and the U.S. to identify any potential benefits or obligations.

Pre-immigration tax planning and reporting are complex processes that require careful consideration of numerous factors, including individual circumstances, tax laws in multiple jurisdictions and long-term financial goals. The support of professionals with expertise in international taxation and immigration law can help ensure a smooth transition and minimize tax-related challenges.

Tax Treaty Interpretation

Our international tax team helps multinational individuals and businesses operating across borders analyze and apply international tax treaties and avoid double taxation on income or gains. Our advisors are adept at leading the way for individuals and businesses to achieve accurate taxation of business and investment income, personal income and pension payments.

Transfer Pricing

To navigate directly to information on Transfer Pricing, click here.