International
Taxation
Foreign assets or operations abroad?
We’ll make sure you’re compliant.
Navigating The Complex World Of International Tax Planning
alliantNational’s team of tax professionals will use
proactive, forward-thinking strategies to help minimize international tax and maximize available foreign
tax credits. Our team can help you plan for intellectual property, support positions taken on tax returns,
guide you through global effective tax-rate planning
and foreign tax credit management.
The time to act is now, and alliantNational can help
defend your interests with:
- Transfer Pricing Documentation and policies
- Risk and opportunity assessments
- Intellectual property valuations
- Cost allocation studies and cost-sharing arrangements
- BEPS, country-by-country reporting, consulting and compliance
International Tax Liability
There are many good reasons why an American
company would spread its business, its assets, and
its operations abroad. Companies that have international clients may want to build up operations in
the areas where their clients are. Companies may
be importing supplies and raw materials and they
may want to move operations closer to the source of
these materials to reduce overhead. To encourage
foreign businesses to set up shop, many countries
offer favorable tax incentives for companies that are
willing to bring in business.
American companies that derive income from
abroad do incur tax liabilities here in the states and
international tax concerns can be extremely complicated. It can be confusing getting a handle on the tax
implications when multiple jurisdictions are involved.
There are complex rules and ever changing regulations that need to be navigated and a mistake can
be costly
International Taxation And The IRS
The IRS’s primary concern is always that it gets its
share of income. The IRS does take certain factors
relating to foreign-source income in calculating a
company’s domestic liabilities. Some of the factors
that the IRS considers in calculating tax liability includes:
- Type of Entity
- Normal return on physical assets
- Income above the normal return (Global Intangible Low Tax Income)
- Income from passive assets
- Profit derived from US based intangible assets
- Taxes paid to foreign governments
The IRS is particularly wary of companies that are attempting to shift income in a foreign country so that
they can reduce the amount of profit they have to
report to the IRS. A lower tax base means a lower tax
liability and the IRS will litigate to ensure it receives
what it believes it is entitled to.
IRS International Tax Penalties
The IRS will penalize companies that do not report or disclose foreign accounts and assets. This includes the following penalty types:
- Civil Tax Fraud
- Failure to Pay
- Penalty for Failing to File Form 8938
- Penalty for Failing to File Form 3520
- Failure to File Report of Foreign Bank and Financial Accounts (FBAR)
We’ll Get You Compliant
If you or your client wants to protect their CIC, the time
to become compliant is now.
alliantNational’s team of experts helps with:
- Risk Pool and UTP Review
- FIN 48 Analyses
- Review and Preparation of Concern Areas
- Review and Analysis of Foreign Bank Report Filings
- Substantiation and Documentation Assistance
- Compliance Review
We’ll Be Your Defense
Already under audit? alliantNational will help you or
your client avoid consequences the IRS are making
consistently more severe, including understatement
and negligence penalties, as well as the potential unwinding of the captive formation and subsequent loss
of benefits.
Thre time to act is now, and alliantNational can help
defend your interests with:
- Audit Defense
- Substantiation and Documentation Assistance
- Risk Assessment of Your Captive
“The nature of tax controversy here
in the U.S. can be complicated enough.
Adding another layer of international
activity makes it that much more complex,
and here at alliantNational we are ready to
help you take on the challenge. businesses
through that daunting process is so
rewarding.”
- Steven Miller
Former IRS Commissioner;
alliantgroup Vice Chairman
INTERNATIONAL TAXATION
Navigating The Complex World Of International Tax Planning
Our team can help you plan for intellectual property, support positions taken on tax returns, guide you through global effective tax-rate planning and foreign tax credit management.
We can help defend your interests with:
alliantNational’s team of tax professionals will use proactive, forward-thinking strategies to help minimize international tax and maximize available foreign tax credits.
Transfer Pricing Documentation and policies
Risk and opportunity assessments
Intellectual property valuations
Cost allocation studies and cost-sharing arrangements
BEPS, country-by-country reporting, consulting and compliance
We can help defend your interests with:
alliantNational’s team of tax professionals will use proactive, forward-thinking strategies to help minimize international tax and maximize available foreign tax credits.
Transfer Pricing Documentation and policies
Risk and opportunity assessments
Intellectual property valuations
Cost allocation studies and cost-sharing arrangements
BEPS, country-by-country reporting, consulting and compliance
INTERNATIONAL TAX LIABILITY
There are many good reasons why an American company would spread its business, its assets, and its operations abroad
Companies expand internationally to be closer to clients and resources, often incentivized by favorable foreign tax policies. However, American companies earning foreign income face complex tax liabilities in the U.S. Navigating multiple jurisdictions’ tax laws is challenging, with costly consequences for mistakes.
INTERNATIONAL TAXATION AND THE IRS
The IRS’s primary concern is always that it gets its share of income.
The IRS focuses on securing its share of income, considering various factors for foreign-source income when calculating domestic tax liabilities:
Type of Entity
Normal return on physical assets
Income above the normal return (Global Intangible Low Tax Income)
Income from passive assets
Taxes paid to foreign governments
INTERNATIONAL TAX LIABILITY
IRS INTERNATIONAL TAX PENALITIES
The IRS does take certain factors relating to foreign-source income in calculating a company’s domestic liabilities.
Civil Tax Fraud
Failure to Pay
Penalty for Failing to File Form 8938
Penalty for Failing to File Form 3520
Failure to File Report of Foreign Bank and Financial Accounts (FBAR)
WE’LL GET YOU COMPLIANT
If you or your client wants to protect their CIC, the time to become compliant is now.
alliantNational’s team of experts helps with:
- Risk Pool and UTP Review
- FIN 48 Analyses
- Review and Preparation of Concern Areas
- Review and Analysis of Foreign Bank Report Filings
- Substantiation and Documentation Assistance
- Compliance Review
WE’LL BE YOUR DEFENSE
The time to act is now, and alliantNational can help defend your interests with:
Under audit? alliantNational helps avoid severe IRS consequences, including penalties and potential loss of captive formation benefits.
- Audit Defense
- Substantiation and Documentation Assistance
- Risk Assessment of Your Captive
