International Tax Services

BKD has an experienced team of international tax professionals, headed by Rob Wagner. This team complements the tax expertise of local partners throughout our 32 offices. Together, these tax professionals can help you with:

Structuring Support

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.  BKD will work with you to determine an efficient structure based on your specific attributes and short-term and long-term goals for the business.

Foreign Tax Credit Planning

A taxpayer’s foreign tax credit planning must be developed based on the specific needs and attributes of the taxpayer.  BKD will review your foreign tax credit position and co-develop a strategy to utilize existing foreign tax credit carryforwards and efficiently utilize foreign tax credits as generated.

Foreign Tax Planning & Compliance Services

Take advantage of our membership in Praxity, AISBL, which gives you access to more than 100 firms in 72 countries with the same high standards as BKD.

Expatriate Assignment Solutions

Reduce your cost while treating employees fairly and help employees meet their tax compliance responsibilities.  BKD’s EAS group can help you address the compliance burdens for employees serving outside the country.

Domestic International Sales Corporation Services

Use of a domestic international sales corporation (DISC) can provide tax savings to U.S. businesses that export goods.  BKD’s international tax team can help you:

• Establish the DISC
• Calculate the DISC commission under available pricing methods
• Prepare accounting records
• Prepare income tax returns
• Identify qualified export receipts
• Plan to meet qualified export property and qualified export asset tests

Transfer Pricing

Transfer pricing investigations by tax authorities are time-consuming and costly.  BKD can help you meet documentation requirements and avoid possible penalties.  In addition, proactive transfer pricing policies and economic analysis often reduce your global tax liabilities.

Fin 48 Analysis

To properly adopt and comply with FIN 48 requires significant research, analysis and documentation.  BKD will work with you to identify your uncertain tax positions, evaluate the strength of your position and quantify the impact.

Inbound Planning

Tax planning for U.S. operations of foreign corporations requires an in-depth understanding of the U.S. law particular to such situations as well as an understanding of the tax treatment to the parent company in its home country.  BKD, through its Praxity™ alliance, has effective working relationship with tax professionals in the parent company’s home country and intervening holding companies, if any.  BKD will work with you with a goal of reducing withholding taxes on payments to foreign-related parties, while taking advantage of allowable deductions in the U.S. to reduce the U.S. tax base. 

Supply Chain Management

Multinational enterprises may have an opportunity to reduce the global effective tax rate by combining supply chain management with tax planning stategies to create a tax efficient operating structure.  BKD and its foreign colleagues through its Praxity alliance can help you take advantage of opportunities in your supply chain to defer U.S. income tax, take advantage of favorable foreign locations and taxing regimes and avoid subpart F income.

Repatriating Foreign Earnings

U.S. based multinationals must understand the complexities of the foreign tax credit before repatriating earnings.  For many businesses, repatriation through dividends, with prior planning, may permit tax effective repatriation at little or no incremental cost or possibly even reducing the U.S. tax burden.  In many cases, more sophisticated longer term planning is required.  BKD can help you determine your facts, develop alternatives, quantify the affect of each of the viable alternatives and make a recommendation based on our understanding of your facts and our experience.

Disposition Planning

Tax planning for divestitures requires upfront analysis to verify your facts and an understanding of the alternatives available to you as you structure a possible sale.  BKD has the experience to help you develop your facts efficiently, to develop alternatives and to quantify the impact. 

Earnings & Profits & Tax Pool Analysis

Knowing your facts is critical to effective tax planning.  Whether you are considering a sale, an internal restructuring or repatriating funds, knowing your earnings and profits and tax pools allows you to make sound decisions that will affect your global tax liability.  BKD will work with you to develop your E&P and tax pools in advance of a repatriation or restructuring project. 

Withdrawal/Exiting a Country

The decision to withdraw from a country creates various planning opportunities to reduce taxes on the exit as well as opportunities to position the owner  for future tax benefits.  BKD can work with you to take advantage of these opportunities and utilize losses upon a withdrawal.

Foreign Business Expansion

Creating a taxable presence in a new country creates a variety of opportunities as well as liabilities for new taxes.  Through our Praxity alliance, we can address your tax needs to keep you in good standing with the tax authorities.  With the appropriate planning, a taxpayer may be able to reduce the combined tax base and the combined effective income tax rate.  BKD can work with you and Praxity colleagues to lower your local country tax liabilities, to build in repatriation strategies and to avoid unnecessary withholding taxes.

Internal Reorganizations

For a variety of nontax business reasons, businesses may reorganize existing foreign operations.  These internal reorganizations create an opportunity to revisit prior tax planning strategies and to introduce new ones.  BKD can work with you and our Praxity alliance to develop a structure that may lower your local country tax liability, allow effective repatriation of earnings and avoid unnecessary withholding taxes.

Foreign Currency Gains & Losses on Branch Activity

Conducting business operations in branch form or in hybrid branch form where the owner and the branch use different functional currencies creates the opportunity to generate foreign currency gains and losses.  These foreign currency gains and losses are recognized under a little known and not well-developed Internal Revenue Code section 987.  The rules regarding section 987 are complex and unsettled, offering taxpayers the opportunity to adopt a variety of different methods to recognize such foreign currency gains and losses.  BKD can help you identify the method that is best for you.  Knowing which method provides the best results will help minimize your federal tax burden.

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