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Our international tax advisors can help you keep your global effective tax rate low and ensure your international transactions are in compliance.

International Tax

Practical, proactive international tax planning

Plante Moran’s international tax specialists excel in providing practical, proactive international tax planning for middle market companies. Whether you are a U.S. company seeking opportunities overseas or a foreign investor seeking opportunities in the United States, our international tax advisors can support you with international tax planning solutions and assist with compliance issues, such as value-added taxes and foreign earnings repatriation.

You can depend on our tax experts to both simplify and minimize the burden of global taxation.

 

Business Tax Compliance

Tax compliance has become increasingly complex as tax authorities attempt to stay ahead of increasingly complex transactions. Plante Moran international tax specialists understand that every business decision has tax consequences. They are committed to keeping you current with international regulatory and tax reporting trends throughout the world.

Expatriate Tax Services

Sending employees from their home countries to work abroad complicates their income tax filing requirements and can create additional tax and regulatory issues for the employer and employees. Plante Moran expatriate advisors can keep employers and employees fully briefed on the issues and in compliance with the tax authorities. Plante Moran experts can also assist in developing policies for employers to ensure that employee benefit packages are adapted to working outside of their home countries; including support with immigration and visa requirements.

M & A

Plante Moran international tax experts have extensive experience helping clients make difficult decisions when purchasing or selling all or a portion of a global business. From due diligence, development of seller-side tax strategies, and joint venture planning, to post-acquisition integration; Plante Moran international tax experts have the deep expertise necessary to make your transaction a success.

Entity Structure

When conducting business on a global scale, entity structure can have a dramatic impact on the effective tax rate of a business. Plante Moran international tax experts can help devise an entity structure that is built specifically around your business and tailored to optimize your global tax situation. From holding companies to “check-the-box”, Plante Moran international tax advisors are experts in structuring to deliver optimal tax results designed specifically for your business.

IC-DISC

Interest Charge – Domestic International Sales Companies are the last great export incentive for U.S. companies. If you are a U.S. company – whether it is an LLC, S Corporation, C Corporation) with exports, an IC-DISC may provide significant tax benefits. Tax benefits come from tax rate differences (qualified dividend rates are lower than ordinary rates) or from deferral of income taxes. Our specialists will determine whether an IC-DISC is appropriate for your company and will assist in the formation, maintenance, and maximization of the benefits.

Indirect Taxes (Value Added Taxes)

The U.S. is the only developed country without a VAT. When U.S. companies expand into other markets they may be charged VAT on purchases or may be required to register for VAT. Our specialists will help your company understand when a VAT may or may not apply to your company. Our specialists will also help an expanding U.S. company understand new shipping terms (Incoterms) and new roles (importer of record) when operating internationally.

Foreign Tax Credit Planning

When a U.S. company begins paying income taxes to a foreign government or when they pay withholding taxes, U.S. tax planning for the foreign taxes paid should follow shortly thereafter. Our specialists will identify foreign taxes that qualify for the foreign tax credit and will work with you to ensure that the foreign source income calculation is correct and allows the largest credit. The foreign tax credit area is complex and we will leave no stone unturned to ensure that credits are obtained for all foreign taxes paid.

Transfer Pricing

Domestic and foreign related companies use an “arm’s length standard” for intercompany transactions to properly report taxable income in each jurisdiction. Our specialists will assist in identifying intercompany transactions, determining arm’s length prices, and documentation that meets IRS and foreign taxing authority requirements. Our specialists can also assist with transfer pricing planning with a focus on minimization of worldwide effective tax rate. Learn more about our transfer pricing practice here.

Cross-border Transactions & Treaty Analysis

Doing business in foreign countries requires a U.S. company to understand how foreign tax laws and the U.S. treaty network interact. Concepts like permanent establishment, withholding taxes, business taxes, and limitation on benefit clauses may have a significant impact on the taxes that a U.S. company pays (or doesn’t pay) to foreign taxing authorities. Our specialists will help you understand potential filing requirements in foreign countries and how to meet those filing requirements.

SALT (State and Local Tax)

Minimizing taxes is a way of increasing cash flow. It’s an easy axiom to understand, but a hard one to execute especially when it comes to state and local taxes. If you are an International company with plans for expansion, relocation, or merger and acquisition, we can help you determine which tax credits, exemptions, and abatements and which financing and infrastructure assistance services are available to you. Legislative, regulatory, and precedent-setting developments in tax are complex and always evolving. Staying on top of all of these state and local tax changes can be very time consuming. That is why so many organizations turn to our State and Local Tax experts who continuously monitor the evolution of state and local tax rules.
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