International Tax and Business Planning

Corporate

  • Structuring U.S. and foreign holding companies
  • Minimizing foreign taxes, utilization of credits
  • Transfers of intellectual property to U.S. and foreign companies
  • Transfer Pricing advise and analysis
  • Tax planning for acquisition of U.S. real estate
  • Withholding tax provisions
  • Planning around income tax treaties
  • Utilization of foreign charitable foundations
  • Foreign tax credit planning and foreign tax minimization
  • Representation on U.S. boards
  • Representation and consulting for cross border mergers and acquisitions
  • Negotiations and client agency duties
  • Advice on cross border licensing

Individuals

  • Nonresident income and estate pre-arrival planning
  • US expatriate planning
  • Compensation planning for US and foreign source income
  • Formation of foreign holding companies for nonresident investing
  • International Social Security Agreements (to eliminate foreign country social security)
  • Foreign deferred compensation planning
  • Lloyd's of London - consulting for U.S. Names
  • Income and estate tax treaty planning
  • Preparation of returns for foreign nationals and U.S. expatriates
  • Consulting regarding use of foreign trusts
  • Utilization of foreign insurance planning
  • Representation before federal and state tax authorities

Foreign Exchange Trading Company

A foreign currency trading company based in Asia needed advise about establishing a U.S. management company to oversea contracts sold in Japan. We consulted on transfer pricing issues and advised how to limit the foreign company's activities in the U.S. by setting up a U.S. subsidiary. The final structures resulted in most of the income remaining offshore and outside the jurisdiction of the U.S. tax net.

Restructuring Inbound Technology

Two U.K. nationals formed a U.S. limited liability company, along with affiliate companies in the U.K. and Malaysia to develop transport (shipping) software. We resolved several transfer pricing issues, and restructured the U.S. company as a Delaware corporation in anticipation of major U.S. investor funding, while keeping the intellectual property offshore for future European licensing transactions.

Foreign Deferred Compensation Trust Eliminates Tax

A foreign executive assigned to the U.S. was required to travel extensively outside the U.S. We established a deferred compensation plan for the executives' compensation related to foreign work. After completion of the three-year assignment, the executive left the U.S., and received the full payout from the plan, plus accrued earnings without incurring any U.S. or home country tax.

Inbound Transfer of Intellectual Property (IP)

IP developed and held in a foreign country was subsequently transferred to the U.S. in conjunction with continued research and development and investor funding. We provided comprehensive international corporate entity restructuring resulting in the IP coming into the U.S. at stepped-up tax cost basis, hence maximizing U.S. amortization deductions.

Minimizing Effective Global Tax Rate

Our client expanded their operations into Europe and Asia. We reviewed and designed their global operating and entity structure in conjunction with legal and tax counsel in each foreign country. The business and legal objectives had to be coordinated with the tax objective of minimizing both local country and U.S. taxes. RCO also set up a foreign sales corporation (FSC) to reduce the effective U.S. tax rate for exports.

Transfer Pricing

A U.S. subsidiary of a foreign company distributes products in the U.S. purchased from its parent company. RCO provided a comprehensive review and audit of the financial statements of the U.S. subsidiary and parent company together with a transfer pricing study to substantiate the inter-company pricing policy.

International Hospitality

This client is a well-known resorts operator with hotels worldwide, including several within the U.S. We provided ongoing tax planning, including a reorganization of their U.S. holdings. U.S. tax was minimized due to effective tax planning on structuring joint venture projects, including effective utilization of losses by filing consolidated returns.

International Technology Venture

Our client is a technology company that has developed valuable IP. The company has partnered with a foreign investor that will provide both funding and technical expertise. We advised on the U.S. operating structure and the offshore intellectual property holding structure to minimize U.S. tax on foreign royalties. Upon liquidation, the company's sale or going public, the foreign investors will not be liable for U.S. tax.

Expatriation

  • Tax research and planning for pre-arrival and pre-departure for U.S. and foreign countries
  • Analyze income and estate tax liabilities
  • Advise and submission of IRS ruling
  • Representation before IRS International office regarding rulings

E-Commerce and Internet

  • Incorporation the new business (California, Delaware and other states)
  • Technology transfers
  • Review merger or venture financing terms for raising capital
  • Taxation of R&D expenditures
  • Business plan review for venture funding
  • Introductions to Venture Capital
  • Review of deal terms for new capital investments
  • Advice on corporate structure for holding IP
  • Introduction to legal counsel (US and foreign) for IP protection
  • Access to investment banking research through firm relationships

New Venture Start-Up Services

  • Structure of organization (partnership, corporation, limited liability company)
  • Accounting systems and management reporting
  • Establishing new banking relationships
  • Assurance services including audit, review and compilation reports
  • Capital structure - debt and equity
  • Business plan - review and development
  • Implement stock incentive plans (qualified and nonqualified plans)
  • Guidance on employee benefit plans
  • Valuation services for stock plans
  • Venture capital introductions where appropriate
  • Serve as director or on corporate and advisory board in selective cases
  • Tax research in all areas
  • Tax return preparation services: income, sales, excise, foreign
  • Representation before IRS and state taxing authorities
  • Assistance with HR functions, hiring, recruiting