This client-centric service model provides dynamic middle market companies with an enhanced understanding of the U.S. and foreign impact of various business decisions, which often impact the profitability of overseas operations as measured by the global effective tax rate. Because tax planning is only one component of international business, we emphasize the need for legal, financial, and operational teamwork so that tax planning evolves within our clients’ overall business objectives.
Our professionals have helped clients at various stages of international expansion:
Two hot areas of transfer pricing for consideration are intercompany loans and cash pooling. These two intercompany financing transactions are used by most multinational entities (MNEs) and are being targeted by the IRS and global tax authorities. Yet, most intercompany loans remain undocumented and have commercial terms that would not meet the required transfer pricing standards.
If you have any foreign assets that have not been reported to the Internal Revenue Service (IRS), it is imperative that you take action now!
The Internal Revenue Service recently announced that the agency will waive certain late payment penalties pertaining to Section 965 of the Internal Revenue Code.
The newly enacted Tax Cuts and Jobs Act (the "Act") gave us what some people refer to as "mandatory repatriation" for previously untaxed foreign earnings of specified foreign corporations. In other words, Section 965 of the Internal Revenue Code now requires some taxpayers to pay tax on the untaxed foreign earnings of certain foreign corporations as if the earnings had been repatriated to the United States. This will take effect for the 2017 tax year for a majority of taxpayers.
US individual shareholders of controlled foreign corporations (CFCs) are currently grappling with the one-time US transition tax on post-1986 deferred foreign income accumulated by their CFCs and the impact of new anti-deferral income inclusion rules referred to as the global intangible low-taxed income (GILTI) provisions, along with other generational changes to the US international tax rules, as the United States transitions from a worldwide tax system to a quasi-territorial tax system.
UHY LLP International Tax & Transfer Pricing Update 201 Presentation
UHY LLP International Tax & Transfer Pricing Update 2018 Video
Bill Kingsley discusses International Tax Reform in Crain’s Detroit Business