International Tax Services
BKD has an experienced team of international tax professionals to complement the tax expertise of local partners throughout our offices. Together, these tax professionals can help you with the following services:
Tax planning is essential to the sale of a subsidiary, division or group of assets. An upfront analysis to verify facts and an understanding of available alternatives is required as you structure a possible sale.
BKD International Tax Services division has the experience to help you develop facts efficiently and analyze and quantify the impact.
Domestic International Sales Corporations
Use of a domestic international sales corporation (DISC) can provide tax savings to U.S. exporters.
The professionals in the BKD International Tax Services division can help you:
- Establish a 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
Earnings & Profits & Tax Pool Analysis
Knowing the facts is critical to effective tax planning. Whether you are considering a sale, an internal restructuring or repatriating funds, knowing your earnings and profits (E&P) and tax pools allows you to make sound decisions that affect your global tax liability. BKD will work with you to examine your E&P and tax pools in advance of a repatriation or restructuring project.
If you have employees working outside the U.S., one of the challenges you face is how to reduce costs while treating employees fairly and helping them meet their tax-compliance responsibilities.
BKD International Tax Services division has the experience to assist you with the many compliance issues you face, including:
- Social Security
- Tax Planning
- Tax Compliance
- Withholding Tax Implications
FIN 48 Analysis
Adoption of, and compliance with, FIN 48 often requires significant research, analysis and documentation. BKD’s International Tax Services division can help you:
- Identify uncertain tax positions
- Evaluate the strength of your position
- Quantify the impact
Foreign Business Expansion
Creating a taxable presence in a new country offers a variety of opportunities but can also bring liabilities for new taxes. Through our membership in Praxity, AISBL, we can help you address your tax needs to keep you in good standing with the tax authorities. With appropriate planning, a taxpayer may be able to reduce the combined tax base and combined effective income tax rate.
BKD International Tax Services professionals, along with our Praxity colleagues, can work with you in an attempt to lower your local country tax liabilities, build in repatriation strategies 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 the little-known and not well-developed Internal Revenue Code Section 987. The rules regarding Section 987 are complex and unsettled, creating the opportunity for taxpayers to adopt a variety of different methods to recognize such foreign currency gains and losses.
BKD International Tax Services division can help you identify the best method for you. Knowing which method can provide the best results can help mitigate your federal tax burden.
Foreign Tax Credit & Tax Planning & Compliance
To help reduce the likelihood of double taxation and meet compliance requirements, BKD’s International Tax Services professionals will review your foreign tax credit position and help you develop a strategy to utilize existing foreign tax credit carryforwards. This will help you more efficiently utilize foreign tax credits as generated.
Our membership in Praxity, AISBL, gives you the advantage of having access to firms in more than 90 countries with the same high standards as BKD.
Tax planning for U.S. operations of foreign corporations requires an in-depth understanding of U.S. law particular to such situations, as well as an understanding of the tax treatment to the parent company in its home country. Through our Praxity alliance, BKD has an effective working relationship with tax professionals in the parent company’s home country, as well as intervening holding companies.
BKD International Tax Services professionals work with you in an attempt to reduce withholding taxes on payments to foreign-related parties, while taking advantage of allowable U.S. deductions to reduce the U.S. tax base.
For a variety of nontax business reasons, businesses may reorganize existing foreign operations. These internal reorganizations create opportunities to revisit prior tax planning strategies and introduce new ones.
BKD International Tax Services division can work with you and our Praxity alliance to develop a structure that could lower your local country tax liability, allow effective repatriation of earnings and avoid unnecessary withholding taxes.
Repatriating Foreign Earnings
U.S.-based multinationals must understand the complexities of foreign tax credits 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 reduce the U.S. tax burden. In many cases, more sophisticated long-term planning is required.
The professionals of BKD International Tax Services division can help you:
- Determine your facts
- Develop alternatives
- Quantify the effect of each viable alternative
- Make recommendations based on our understanding of your facts and experience
When acquiring or establishing operations in new jurisdictions, the legal entity structure taxpayers choose likely will affect the global effective tax rate for the enterprise and its shareholders. With appropriate planning, however, a taxpayer may find the right structure to reduce the global effective tax rate.
BKD International Tax Services division professionals can work with you to determine an efficient structure based on your specific attributes and short-term and long-term business goals.
Supply Chain Management
BKD International Tax Services professionals can help you identify opportunities in your supply chain that may allow you to defer U.S. income tax, take advantage of favorable foreign locations and taxing regimes and avoid Subpart F income.
Tax Due Diligence for International Investments
If you are considering investing in a business with foreign operations, assessing the tax position of the target company can have a significant impact on its enterprise value or the representations and warranties required to complete a deal.
BKD International Tax Services division can help investors identify U.S. tax risks associated with foreign investments and, through our membership in Praxity, AISBL, provide assistance with local country tax due diligence.
Transfer pricing refers to the pricing of goods, services or intangibles within a multinational organization, particularly in regard to cross-border transactions.
The vast majority of global trade occurs between related-party entities. As global trade increases, companies are confronted more and more with complex issues associated with intercompany pricing. This is compounded because many countries have specific transfer pricing legislation, and the tax authorities within those countries aggressively pursue transfer pricing adjustments. It is no wonder transfer pricing is often listed as the single most important international tax issue facing multinational companies. Learn More
U.S. Tax Compliance
Now more than ever, compliance with U.S. international information reporting requirements is a top priority for multinational businesses. BKD International Tax Services division professionals can help you navigate the complex rules for reporting international activities so that your filing obligations can be filed accurately and timely, avoiding costly penalties and unnecessary tax exposure.
Withdrawal/Exiting a Country
The decision to withdraw from a country creates various planning opportunities to reduce taxes on exit, as well as opportunities to position the owner for future tax benefits.
BKD International Tax Services division can work with you to take advantage of these opportunities and potential losses upon a withdrawal.