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International Tax & Business Services

Addressing Challenges & Opportunities in the Global Marketplace

We serve U.S.-based companies that do business internationally as well as foreign-based companies that operate within the U.S. We manage the needs and objectives required at the local, regional, national and international levels as imposed by international tax laws and accounting regulations and navigate the complexities of foreign business structure.

Frazier & Deeter’s International team includes bilingual professionals who are available facilitate communications. We support your business needs with fluency in key European languages such as French, Spanish, Russian, as well as multiple Chinese dialects, Japanese, Hebrew, Hindi, Farsi and more.

A Global Approach to Tax Strategy

Our team of specialists can assist you in evaluating where tax efficiencies can be achieved on a global basis by focusing on cross-border transactions and the structure utilized. To do so, we concentrate on six primary areas.

1. Global Tax Strategies
Focus on operations and cross-border transactions to evaluate available alternatives to achieve tax efficiencies

2. Global Transfer Pricing
Focus on cross-border transactions with attention to debt, services, tangible property and intangible property. Emphasis on using transfer pricing as a strategic tool while meeting the global compliance requirements.

3. Global Human Capital
Focus on movement of personnel globally and the activities they undertake in a country. Drive to gain tax efficiency for the employee with an eye toward minimizing entity-level tax.

4. Global Indirect Taxes
Focus on cross-border transactions and the minimization of GST/VAT and related compliance on such transactions.

5. Global Trade & Customs
Focus on cross-border transactions, reviewing the impact of customs and duties on such transactions.

6. Global Compliance Matters
Focus on the coordination and collaboration with local country tax professionals to ensure local country tax return filings and elections are completed in a timely manner.

International Tax Services Available:

  • Choice of entities
  • Developing tax strategies
  • Due diligence on expansion opportunities
  • Permanent establishment rules
  • Planning and implementing export incentives
  • Planning for asset transfers between U.S. and foreign companies
  • Planning for outbound and inbound executives
  • Reporting and disclosure rules
  • Strategies for repatriating income
  • Structuring foreign sales corporations
  • Techniques for repatriation of earnings and use of foreign tax credits
  • Using income and estate tax treaties
  • Income tax treaty planning and strategies
  • Expatriate consulting
  • Inbound and outbound business start-up services
  • Foreign asset protection
  • Transfer pricing studies
  • Passive foreign investment company analysis

Podcast | Untangling the Technical: Expanding to the UK: Understanding the Landscape

The UK is the fifth largest economy in the world, and its stated goal is to be business friendly from a tax perspective. Join two international tax experts to learn about some of the tax implications of expanding to the UK, including VAT, employment taxes, transfer pricing, R&D incentives and more.

Podcast | Untangling the Technical: Making the jump to the US: What UK companies need to consider

The US is an enormous market that offers tremendous opportunity. Recent changes to the American tax code make this market even more attractive, but there are still many differences that are important to understand when considering expansion into the US. Join Mike Whitacre and Malcolm Joy, two of our international tax experts, to learn about some of the tax implications of doing business in the US, including setting up an entity, state and local tax regimes and tax incentives.

Article | IRS Again Waives Repatriation Tax Penalties

In its third action this year, the IRS announced that it will waive additional late payment penalties for the repatriation transition tax on offshore profits. More guidance is also provided on how individuals subject to the tax make elections.

Podcast | Untangling the Technical - Breaking Down Brexit: On the Brink

Join Malcolm Joy, the Lead Partner of our London office, and Mike Whitacre, one of the leading partners in our International Tax Practice as they discuss the current status and potential tax implications of Brexit.

Article | Foreign Bank Account Reporting (FBAR) Explained

Do you have a bank account, brokerage account, mutual funds, trusts or other financial accounts outside of the U.S.? Here’s what you need to know about FBAR IRS reporting, including who reports all subjected accounts and clarification of the $10,000 minimum value requirement.

Article | Foreign Account Disclosures

The IRS now imposes a 50% penalty on any foreign financial institution responsible for offshore tax evasion by individuals. Understand updates to the rules of the Offshore Voluntary Disclosure Program and the hard lines set by the Foreign Account Tax Compliance Act (FATCA).

Podcast | Untangling the Technical - New International Tax Law Implications

Frazier & Deeter’s International Tax guru Mike Whitacre discusses the implications for U.S. businesses with foreign earnings as well as foreign companies with U.S. businesses.

U.S Tax Reform: Implications for Multi-National Companies

The Tax Cuts and Jobs Act contained sweeping changes which impact your tax planning starting immediately. Our expert Mike Whitacre reviews these changes and how they may affect your company.

International Business Expansion 

Learn the critical questions to ask before expanding your business internationally, including validation of markets and customer bases, as well as cultural differences and legal structuring.

Currency Repatriation for International Business

Understand the legal and financial responsibilities of your global treasury function. Learn how withholdings and foreign tax credits can affect your maximum available assets.

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