Domestic International Sales Corporations (DISC)
The use of a DISC can provide tax savings to U.S. exporters. In addition to helping establish and calculate the DISC commission under available pricing methods, BKD can assist in preparing accounting records and income tax returns and identifying qualified export receipts.
Foreign Tax Credit & Tax Planning & Compliance
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 compliance requirements and reduce the likelihood of double taxation, BKD can assess your foreign tax credit position and help you develop a strategy to use existing foreign tax credit carryforwards. This will help you more efficiently use foreign tax credits as generated.
Foreign-Derived Intangible Income (FDII) & Global Intangible Low-Taxed Income (GILTI)
The Tax Cuts and Jobs Act introduced two new international tax provisions. BKD can help you take advantage of the new FDII export incentive to reduce your U.S tax burden and help you analyze the effect of the new GILTI inclusion, deduction and foreign tax credit associated with income earned in foreign corporations.
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 can help you find an efficient structure based on your specific attributes and short-term and long-term business goals.
Foreign Currency Gains & Losses on Branch Activity
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. BKD can help you navigate these rules and maintain documentation to calculate currency gains and losses under these complex rules.
U.S. & Foreign Tax Compliance Services
Now more than ever, compliance with U.S. international information reporting requirements is a top priority for any multinational business. BKD can help you navigate the complex rules for reporting international activities to verify your filing obligations are filed accurately and on time, avoiding costly penalties and unnecessary tax exposure.
Our tax technology suite offers web-based tools for data collection, collaboration and knowledge sharing. BKD can coordinate foreign tax compliance through the Praxity, AISBL, alliance firms and Huddle—a leading cloud-based collaboration tool that allows us to share files and collaborate with you in a central online environment. BKD understands the importance of working closely with clients and third-party tax professionals to share files and manage international tax projects.
Our membership in PraxityTM gives you the advantage of having access to firms in more than 100 countries with the same high standards as BKD.
Tax Due Diligence for International Investments
If you’re 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. BKD 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.
Global Mobility Services
If you have employees outside the U.S., you’re likely looking to reduce costs while treating employees fairly and helping them meet their tax compliance responsibilities. BKD has the experience to assist you with many compliance issues, including Social Security, tax planning, tax compliance and withholding tax implications.