Global Tax Strategy

Top-performing companies understand that their supply chain and underlying core business model provide a critical source of competitive advantage. Experience shows that companies with the best-performing supply chains rank ahead of their competition on key financial metrics. These companies ensure that their supply chains fully support not just their overall business strategies, but also well-defined global tax strategies.

While supply chain and business model optimization help companies gain their competitive footing, there are multifaceted tax, operational and organizational implications that are wide in scope. For many companies, the complexity is compounded by business operations and supply chains that are spread or rapidly expanding throughout the world. Solutions must be business-driven, holistic, forward-looking, develop a solid foundation for sustainable growth, and flexible to adapt to frequently changing global tax, economic and business factors.

The international tax and transfer pricing experts in BPM’s Global Business Model Optimization Group have extensive experience with supply chain and business model optimization. We provide value-added hands-on analysis, direction and support on tax, operational and other organizational matters to ensure that your company’s supply chain and legal structure aligns with your core business model and supports relevant tax and business strategies at the global and local country levels. We design, develop and implement tax-effective supply chain and business model optimization strategies that consider and bring together these critical factors to help achieve optimum and sustainable operational, tax and other financial results.

Foreign-based companies seeking to expand into the U.S. or increase existing U.S. operations or investments need specialized expertise to properly identify and address the myriad U.S. and foreign tax issues relevant to them, particularly in today’s rapidly evolving, increasingly complex U.S. tax and business environment. Our dedicated ITS professionals have the in-depth expertise and relevant experience with U.S. inbound tax planning to provide cost-effective, value-added assistance to foreign-based companies that are establishing or expanding their U.S. footprint.

Our ITS professionals work with foreign-based companies operating in all global industry and business sectors and geographic markets to identify, develop, implement and maintain a company-specific tax-effective U.S. expansion strategy and tactical game plan that facilitates and enhances their U.S. and global business and financial successes.

Our ITS professionals help foreign-based companies identify, properly evaluate and balance all U.S. and foreign tax and related considerations relevant to U.S. expansion, including:

• Optimum timing of U.S. investment or expansion
• Choice of location(s) for U.S. activities
• Choice and characterization of U.S. inbound activities
• If and when a U.S. entity is necessary
• Choice of U.S. entity: branch, subsidiary or hybrid entity
• Choice of state for U.S. incorporation or organization
• Use of U.S./foreign joint ventures and partnerships
• Use of U.S. employees versus contractors
• U.S. inpatriate assignments – structuring and tax compliance
• Capitalization and financing of U.S. inbound operations
• Cross-border use or transfer of intangibles
• U.S. inbound transfer pricing strategy and documentation
• Stewardship, management and back-office support
• U.S. multi-state tax planning
• U.S. income and withholding taxes – rates and reduction
• U.S. double tax treaties – benefits and eligibility
• U.S. Federal and state income tax compliance

As U.S. companies grow internationally, they frequently arrange foreign work assignments for their U.S. employees. Whether foreign work assignments are intended to be less than a year in duration or for a more extended period of time, proper planning and compliance with multifaceted U.S. and foreign tax laws and other regulatory requirements is critical to protect a company’s legal, reputational and business risks.

BPM’s International Assignment Tax Services (IATS) professionals have the relevant expertise to ensure tax and cost-efficient results for U.S. and foreign companies and employees. We offer specialized experience in the financial and compensation elements of international assignment programs that contribute significant value to the employer and enhance the employee’s international assignment experience.

When foreign support on international assignment matters is needed, BPM’s Allinial Global network provides direct and immediate access to “home country” international assignment expertise and services in the more than 106 countries where our 220 member firms operate.

IATS services we provide include:

• Planning for tax and cost-effective short-term assignments of less than one year
• Planning for tax and cost-effective long-term assignments of one year or longer
• Design and administration of employee tax protection and equalization programs
• Consulting on U.S. and foreign benefit plans and social security matters
• Assistance with U.S. and foreign payroll, withholding, reporting and filing requirements
• U.S. and foreign tax compliance services and support for companies and assignees

Mid-market and early-stage companies that embark upon or increase their global expansion often lack the internal expertise or resources required to properly identify or address the myriad U.S. and foreign tax and non-tax issues of relevance, particularly in today’s rapidly evolving, increasingly complex global tax and business environment.

We specialize in mid-market and early-stage companies, offering the complete range of U.S. and foreign international tax and transfer pricing services. Our ITS professionals have the in-depth expertise and relevant experience to provide cost-effective, value-added assistance to mid-market and early-stage companies that are establishing or expanding their international footprint. We assist companies operating in all global industry and business sectors and geographic markets to identify, develop, implement and maintain company-specific tax-effective international expansion strategies and tactical game plans that facilitate and enhance their global business and financial successes.

Our ITS professionals can help mid-market and early-stage companies identify, properly evaluate and balance all U.S. and foreign tax considerations relevant to their international expansion, including:

• Capitalization and financing of cross-border operations
• Choice of country and location therein
• Choice of foreign entity: branch, subsidiary, hybrid, joint venture, partnership
• Cross-border use and transfers of intangibles
• Double tax treaties – availability, eligibility and benefits
• Expatriate assignments – planning, tax compliance and equalization
• Foreign income and withholding taxes – rates and reduction opportunities
• Foreign tax holidays and incentives
• Holding company regimes
• Identification and characterization of cross-border activities
• Optimum timing for expansion
• Stewardship, management and back-office support
• Transfer pricing strategy and documentation
• U.S. and foreign tax compliance matters 
• Use of foreign employees versus contractors
• VAT and GST – indirect tax registration, reporting and costs 
• When use of a foreign entity is necessary

All U.S. and foreign transactions involving business combinations or restructurings raise highly complex tax issues and risks, while also providing significant opportunities to achieve tax-effective transaction results and tax-efficient future structures and operations. These transactions include mergers, acquisitions, joint ventures, partnerships, equity investments, divestitures, and “inversions.”

The extent and significance of the tax issues, risks and opportunities on these transactions is compounded when multinational companies or multiple jurisdictions are involved. When not proactively identified and addressed by professionals with relevant expertise, the window to avoid potential tax pitfalls and achieve optimum tax results may close when the transaction closes.

Our dedicated ITS professionals offer deep expertise and extensive experience in all aspects of international business combinations and restructurings, including post-transaction integrations. Our ITS team can assist U.S. and foreign companies involved in these transactions with proactive identification of all relevant U.S. and foreign tax issues, risks and opportunities. They can also identify, develop, and assist in implementing company-specific strategies for achieving tax-effective transaction results, post-transaction integrations and future operating structures.

When foreign support on international business combinations is needed, BPM’s Allinial Global network provides direct and immediate access to the same high level of “home country” expertise and resources in the more than 106 countries where our 220 member firms operate.

BPM offers additional expertise and a comprehensive suite of other services relevant to international business combinations, including due diligence, modeling, valuation, financing, financial reporting and tax compliance.

Early-stage and mid-market companies frequently lack the internal expertise or resources required to properly identify or comply with the myriad tax compliance requirements in the U.S. and foreign countries in which they operate. Even multinational companies with mature, well-staffed tax departments face formidable challenges and potentially significant risks coping with U.S. and foreign tax compliance requirements in today’s rapidly changing and increasingly rigorous global tax environment.

Adding to the international tax compliance burden is FASB Interpretation (FIN) Number 48, Accounting for Uncertainty in Income Taxes. This law deals with the proper recording of tax positions for financial statement purposes and has contributed to significant financial reporting confusion and increased burdens in recent years. That is particularly the case with proper recording of international tax positions, which can involve understanding and analysis or complex foreign tax rules and their interplay with the U.S. international tax rules.

BPM offers efficient, cost-effective U.S. and foreign tax compliance and tax provision services and support, including co-sourcing and outsourcing options. We help multinationals gain greater confidence in their level of compliance through improved data management and by determining data integrity and accuracy. We help manage risk, provide more timely and transparent reporting and improve overall compliance efficiency by automating and systematizing routine and repetitive tasks.

When foreign support on international tax compliance or tax provision matters is needed, BPM’s Allinial Global network provides direct and immediate access to local tax compliance and tax provision expertise and services with over 200 member firms.

Our comprehensive international tax compliance and tax provision services, includes preparation and consultation on the following:

• Form 1120F – U.S. tax return of U.S. inbound companies
• Forms 5471 and 5472 – U.S. information reporting returns
• Form 8858 for foreign branches and disregarded entities of U.S. companies
• Foreign tax credit – optimization, redeterminations, forecasting and planning
• Expense apportionment – 861-8 and headquarters expense optimization
• Overall Foreign Loss (OFL) and Dual Consolidated Loss (DCL) studies and planning
• Subpart F – effective tax rate computation, analysis and planning
• Earnings and profits (E&P) – computation, analysis and planning
• Foreign tax pools – computation, analysis and planning for FTC, Subpart F, repatriation
• Tax basis studies – computation of outside share basis and inside asset basis
• Passive Foreign Investment Company (PFIC) returns for companies and shareholders
• Form 8938 for specified foreign bank accounts and other assets
• Foreign Account Tax Compliance Act (FATCA) registration and reporting