International Tax Services

When acquiring or establishing operations in new jurisdictions, the legal entity structure taxpayers choose will likely affect the global effective tax rate for the enterprise and its shareholders. Conversely, with appropriate planning, a taxpayer may find the right structure reduces the global effective tax rate. FORVIS can help you identify an efficient structure based on your specific attributes and short-term and long-term business goals.

The Tax Cuts and Jobs Act introduced two new international tax provisions. FORVIS can help you take advantage of the FDII export incentive to reduce your U.S. tax burden and help you analyze the effect of the GILTI inclusion, deduction, and foreign tax credit associated with income earned in foreign corporations.

While the Tax Cuts and Jobs Act moved the U.S. from a worldwide tax system to a modified territorial system with dividends from foreign corporations generally being exempt from U.S. taxation, foreign tax credits can still be relevant in certain situations. To help meet information reporting and compliance requirements and reduce the likelihood of double taxation, FORVIS can assess your foreign tax credit position and help you develop a strategy to use existing foreign tax credit carryforwards. This may help you more efficiently use foreign tax credits as such credits are generated.

FORVIS understands the difficulties nonprofit and public sector organizations face in obtaining funds to further their exempt purpose or secure retirement benefits for their plans’ beneficiaries. That is why we are passionate about helping organizations navigate the process of reclaiming foreign withholding taxes to avoid leaving money on the table.

Has your organization been informed of the opportunity to obtain refunds of foreign withholding taxes on investment income, but you do not know how to manage the reclaim process? FORVIS can help provide proactive, tailored guidance and the resources you require to file a claim for refund, including reclaim analysis, documentation preparation and assistance, preparation and submission of claims, as well as claim denial investigation and resolution.

Conducting business operations in branch form or hybrid branch form, where the owner and branch use different functional currencies, can create an opportunity to generate foreign currency gains and losses recognized under Internal Revenue Code Section 987. The rules regarding §987 are complex and require taxpayers to recognize such foreign currency gains and losses. FORVIS can help you navigate these rules and maintain documentation to calculate currency gains and losses under these complex rules.

The use of a DISC may provide tax savings to U.S. exporters. In addition to helping establish and calculate the DISC commission under available pricing methods, FORVIS can assist in preparing accounting records and income tax returns and identifying qualified export receipts.

If you are considering investing in a business with foreign operations, assessing the tax position of the target company can have a significant effect on its enterprise value or on the representations and warranties required to complete a deal. FORVIS can help investors identify U.S. tax risks associated with making a foreign investment. Through our membership in Praxity™, we have access to tax professionals in more than 100 countries to help provide local country tax due diligence assistance.

Transfer pricing refers to the pricing of goods, services, or intangibles within a multinational organization, particularly regarding cross-border transactions.

FORVIS offers cost-effective transfer pricing assistance based on an understanding of your business. Through our membership in Praxity we can draw on transfer pricing professionals worldwide to serve the needs of multinational clients.

If you have employees moving inside or outside the U.S., you are likely looking to reduce costs while treating employees fairly and helping them meet their individual tax compliance needs. FORVIS has the expertise to assist you with many compliance issues, including Social Security tax planning, income tax planning and compliance, as well as withholding tax implications. 

FORVIS’ Global Tax Integration® team is dedicated to helping global companies navigate the growing number of tax rules and regulations across the world.

As foreign organizations move goods, services, and production to the U.S., a number of issues can arise. FORVIS can assist your organization with tax planning and international imports for inbound services.

Praxity™ has teamed up with the International Bureau of Fiscal Documentation to produce country-specific tax guides. These guides provide guidance on business investment, individual and corporate rates and regulations, socio-demographics, economy, culture, and distinctive business characteristics of each country.

FORVIS annually prepares thousands of tax returns for individuals, various types of businesses, trusts, and tax-exempt entities. We also provide a variety of tax planning and consulting services.

FORVIS can provide the following quantitative services:

• Earnings and profits analysis
• Expense allocation and apportionment for foreign tax credits
• Sourcing of income
• Transfer pricing analysis
• IC-DISC commission computation on varied approaches
• Measuring impact of foreign currency on monetary transactions
• Deemed dividend computations (Subpart F and Section 956)
• Computation of GILTI Tested Income
• Base Erosion and Anti-Abuse Tax (BEAT) analysis and related computations
• Measuring foreign derived deduction eligible income