China passes Corporate Income Tax Law
U.S.-Canada Income Tax
Certain activities, functions and assets of the company were transferred to new entities and taxing jurisdictions. BKD performed a transfer pricing analysis to determine arm's-length prices for intercompany transactions resulting from the restructured company and its affiliates.
The result: The company's income tax liability has been reduced by $1 million annually.
Many U.S. accounting and consulting firms no longer provide international tax consulting to mid-sized businesses. BKD recognizes that mid-sized as well as larger companies are players in the international marketplace, and we are committed to helping them compete successfully while complying with international tax rules. International Tax Brochure BKD Tax Feature: New Enterprise Income Tax Law in China
BKD has an experienced team of international tax professionals, headed by Rob Wagner. This team complements the tax expertise of local partners throughout our 27 offices. Together, these tax professionals can help you with:
Structuring Support
Set up the right type of operation to reduce your foreign and U.S. taxes. BKD helps you establish a tax-efficient structure to enhance tax deferral opportunities and avoid antideferral tax traps, i.e., sub-part F provisions.
Foreign Tax Credit Planning
Discover how to use tax credits and save money. Many U.S.-based multinational companies find themselves with an excess foreign tax credit. BKD identifies Internal Revenue Code provisions to reduce the likelihood of double taxation and utilize foreign tax credit.
Foreign Tax Planning & Compliance Services
As a member of Praxity, AISBL, BKD can help you with foreign tax planning and compliance. Praxity, a global alliance of independent firms, gives multinational clients access to professional accounting and auditing firms committed, as we are, to the high standards required in international business.
Expatriate Assignment Solutions
Take advantage of business opportunities through the international mobility of your labor. BKD designs tax equalization policies and compensation packages that reduce your costs while treating employees fairly. We ensure employees meet their regulatory filing responsibilities so they can concentrate on their job responsibilities, not tax concerns. You and your employees benefit directly from tax and Social Security savings.
EI Exclusion Services
If you're active in exporting your company's goods abroad, BKD's extraterritorial income (EI) exclusion professionals can help you lessen the U.S. tax on your export profits for open tax years. These benefits are available even though your business operates in a pass-through (S corporation) or unincorporated (partnership, LLC, LLP) form. We can help you:
- Analyze sales transactions for EI exclusion qualifications
- Meet foreign economic process requirements
- Quantify and allocate associated expenses
- Review transactional pricing calculations
- Select sales grouping methods to enhance your benefit under existing EI rules
- Provide documentation to help you withstand IRS challenges
Domestic International Sales Corporation Services
EI exclusion is repealed after December 31, 2006. The domestic international sales corporation (DISC) is the only remaining export incentive available to U.S. businesses. 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
- Determine qualified export receipts
- Meet qualified export property and qualified export asset tests
Transfer Pricing Reviews
Transfer pricing investigations by tax authorities are time-consuming and costly. BKD helps you meet documentation requirements and avoid possible penalties. In addition, proactive transfer pricing policies and economic analysis often reduce your global tax liabilities.
For More Information
Contact your BKD advisor or:Rob Wagner
Partner
317.383.4187
