Business Tax Services

In many instances, companies have foreign subsidiaries with limited business activities, or the sole purpose of which is to provide intercompany services to the parent. The parent companies also routinely provide management and administrative services to their foreign affiliates. Some of these entities are cost centers by design and have to be structured accordingly with the arms’ length principle and transfer pricing documentation in mind. We can advise you on simple cost plus arrangements, as well as more complex methodologies, such as licensing or return on sales arrangements. We can assist you in guiding you through a process of setting up your transfer pricing methodology, which may be reflected in a benchmarking analysis or a planning transfer pricing analysis, or we can prepare a robust transfer pricing study that would provide transfer pricing penalty protection. We will support you in implementing the adopted transfer pricing methodology and assist you in case of a CRA or IRS audit. Where applicable, we will also assist you in requesting the assistance of the US or Canadian Competent Authorities to resolve your most complex transfer pricing adjustments or controversy. For larger businesses, we will advise you on securing an Advance Pricing Agreement (“APA”) with the IRS and applicable foreign jurisdictions.

Our firm handles U.S. tax compliance needs ensuring that your company meets all tax requirements, across all jurisdictions, in an effective and timely manner. We can complete and advise on the filing and preparation of required forms and schedules for all types of legal entities, from sole proprietors to global corporations, including consolidated return preparation and filing.

U.S. entities and U.S. individuals are required to report to the IRS on your ownership of any non-U.S. entity in which you owned or owned at least 10 percent by filing Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. Failure, inaccurate or late filing of this Form results in an automatic US $10,000 penalty (per form) from the IRS. Even if an entity is inactive or losing money, the penalties will apply assuming they are required to file the Form. IRS Forms 926 and 5472 are other forms that a company may be required to file to report intercompany transactions, such as cross-border dividends, capital infusions and loans. These international information returns are not exclusive to US persons, they may also be required to be filed by foreign entities with US affiliates, shareholders, or subsidiaries. Often companies are not aware of the full scope of Forms that they are required to file. Our firm can assist in bringing your company into compliance with the IRS. Our expertise allows us to navigate the rules in an attempt to prevent the triggering of any automatic penalties, generally by requesting a penalty abatement with the appropriate authorities by asserting a reasonable cause defense. Other countries also have similar reporting regimes around controlled foreign corporations (“CFCs”) or cross-border activities, which we can advise you on.

If you are a US entity or a US resident individual and have over US $10,000 in a foreign (non-US) bank account at any moment during the year, or even just signature or other authority over such an account (for example, having online access to a foreign bank account that is not yours but where you have the authority to initiate and approve wire transfers counts as such ‘other’ authority), you have triggered another compliance requirement – the filing of Form FinCen 114, Foreign Bank Account Reporting (“FBAR”) with the Financial Crimes Enforcement Network. We will be happy to help you stay in compliance with these highly sensitive regulations.

If you or your company has to file a set of financial statements, or present statements to current or potential investors, your tax provision becomes an vital piece of information. Our team can help with global tax accounting needs, such as building a complete tax provision work-paper, including an effective tax rate reconciliation, a deferred tax inventory, a tax basis balance sheet, a current tax payable / receivable analysis, and all the required disclosures. A quality tax provision is a good tool for a planning discussion and a solid basis for your tax filings.

Merger and Acquisition transactions often happen quickly and when you least expect them. Our team can assist you in preparing for due diligence activity, allowing you to go through the process in a n effortless way. We will analyze the purchase accounting aspects of the transaction and tax accounting matters will be addressed through this process. There are a number of elections and positions available under the Internal Revenue Code when a transaction occurs, for instance: an IRS Section 338(g) election on a foreign target can provide some tax benefits in the long run, an IRC Section 83(b) election is a smart move when investing in early stage startups. We can also assist by analyzing the deal and transaction costs to determine eligibility under relevant country rules.

Maintain a tax compliant business for owners, shareholders and employees is crucial. When cross border transactions, cross border workers and executives traveling across borders come into play, the complexities and compliance required are elevated. Our team of professionals can help pre-plan your businesses tax preparation service or take over your current service to help bring you, your business and employees in compliance with U.S. tax law. We will work with all levels of your business to ensure that the proper reporting requirements are met and can help evaluate whether or not filing is required.

Our firm handles U.S. tax compliance needs ensuring that your company meets all tax requirements, across all jurisdictions, in an effective and timely manner. We can complete and advise on the filing and preparation of required forms and schedules for all types of legal entities, from sole proprietors to global corporations, including consolidated return preparation and filing.

Tax risks are probably the most sensitive item in the world of business. You may have a successful profitable enterprise with a strong balance sheet, but potential buyers, investors and partners will hesitate if they hear of a tax exposure. Many deals fall through before closing when an undisclosed tax risk popped up. We will help you manage and minimize your tax risks and help provide Tax risk management tools, including drafting proper documentation of uncertain tax positions and potential unrecognized tax benefits.

When business have been active for a long period of time, they may find themselves in the crosshairs of a “tax audit.” This can come from a qualified team of tax professionals, rather than tax authorities, who can identify any issues and areas that require re-evaluation and some attention, including potential restructuring or structure simplification. We can prepare a pre-emptive due diligence, on a small scale, that would give you a unique look at your tax situation. We can also provide comments and recommendations on how to optimize your situation if the tax circumstances surrounding your business have been stagnate.  

If you are a US entity or a US resident individual and have over US $10,000 in a foreign (non-US) bank account at any moment during the year, or even just signature or other authority over such an account (for example, having online access to a foreign bank account that is not yours but where you have the authority to initiate and approve wire transfers counts as such ‘other’ authority), you have triggered another compliance requirement – the filing of Form FinCen 114, Foreign Bank Account Reporting (“FBAR”) with the Financial Crimes Enforcement Network. We will be happy to help you stay in compliance with these highly sensitive regulations.