U.S. Corporate Tax And Tax Planning
International Tax Planning
U.S. Corporate Tax And Tax Planning Services
- Tax return preparation and filing for domestic and multi-state tax planning and preparation for:
- U.S. corporations
- U.S. partnerships
- U.S. limited liability companies
- Tax reporting for:
- U.S. companies doing business abroad
- Foreign companies doing business in the U.S.
- Department of Commerce filings
- New ventures
- Selection of most efficient operating structure
- Debt and equity capitalization
- Capitalization of company with common and preferred stock
- Representation before taxing authorities
- Negotiations with federal, state and local authorities
- Corporate compensation and stock plan reviews
- Federal, state and international tax compliance reviews
- State tax planning
- State income tax review
- Sales and use tax review and local tax nexus review
- Review of apportionment methodology among states
- Use of local vs Delaware holding companies
- FAS 109 and FIN 48 Tax Provision services
- Determination of effective tax rate for company
- Disclosure of deferred tax assets and liabilities
- Purchase accounting issues
- Stock compensation issues
- Determination of valuation allowance and release of allowance
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International Tax Planning Services
- U.S. company expanding operations overseas
- Foreign branch vs subsidiary operations in the U.S.
- Transfer of assets to foreign affiliates, both taxable and nontaxable
- Coordinating U.S. and foreign taxes
- Personnel relocation issues
- Tax Equalization Planning
- Expatriate tax return preparation
- Corporate payroll planning
- Benefit plans in U.S. and foreign jurisdictions
- Analysis of foreign country tax environment
- Foreign company expanding into U.S.
- International structure planning
- Branch vs incorporation
- Debt vs capital consolidations
- Tax treaty analysis
- Withholding tax planning
- Foreign tax credit reviews
- International transfer pricing
- Pricing and cost analysis to minimize foreign taxes
- Cost sharing agreements
- Management agreements
- Documentation requirements to reduce penalty exposure
- Full study
- International compensation planning
- Per diem plan to reduce U.S. payroll taxes
- Tax treaty applications for transfers to U.S.
- Foreign deferred compensation plans
- International Social Security agreements for avoiding double tax
- Tax equalization plan drafts and reviews
- Stock option issues re: cross-border moves
- Real estate holding structures (special rules for foreign investors)
- Appropriate holding structure for owning and operating in the U.S.
- Minimizing withholding and branch taxes for inbound investments of U.S. real property
- Incorporation, operations and liquidation analysis
- Structuring cross-border tax-free debt instruments
- Cross-border mergers and acquisitions
- Dual country tax coordination and repatriation of profits
- Minimizing withholding taxes on foreign partners
- GAAP and local country accounting coordination
- Tax preparation for all entities
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To discuss your U.S. and cross-border business tax needs, call Rowbotham & Company at +1 (415) 433-1177.