U.S. Cross-Border Tax Services for Business
Our firm focuses on providing cross-border and U.S. tax planning, structure, consulting and compliance services for small and medium size businesses. We are engaged in all aspects of business operations, both during the start-up phase and mature business.
We help our clients with pre-planning advice and basic guidance, as well as more sophisticated tax strategies and solutions when our clients are faced with tax challenges during any stage in their business cycle. Our team has over 40 years of experience advising business clients in various areas of cross-border, U.S. international taxation, and transfer pricing.
Business Planning
- Entry Into the United States and Canadian Markets
- Funding, Financing and Capital Transactions
- Start-Up Business Planning and Structuring, including feasibility assessments
- Check the box tax planning for international tax planning
- Subpart F and Controlled Foreign Corporations planning
- Passive Foreign Investment Company planning
- Complex International Planning
- Business and investment matters
Entry Into the United States and Canadian Markets
While beginning a new business or expanding an existing business model to another North American market can appear easy for competent business owners, careful consideration must be given towards tax considerations on both sides of the border. Which type of legal entity should you use to structure your business? How will the business be funded? How will income be distributed? Are you going to have U.S. citizens working or owning the business? How can you bring profits across the border in a tax efficient manner? There are many things to consider when looking to expand or create a new business with cross-border desires. US Tax IQ has assisted in a variety of consulting, implementation and tax compliance aspect of business expansion and creation.
Business Maintenance and Tax Preparation
- Cash Repatriation Matters and Cross Border Dividends
- Intercompany Service Arrangement, Transfer Pricing Matters
- U.S. Federal, State and Local Tax Compliance and Preparation
- U.S. International Information Reporting
- U.S. Foreign Bank Account Reporting
- Tax Provision Support
- M&A Activity Support
- Corporate reorganizations and approaches for selling U.S. based businesses
- Tax Planning and Preparation for Employees
- Tax for C Corporations, S Corporation and Limited Liability Companies
Cash Repatriation Matters & Cross Border Dividends
For businesses producing profits, the method and ramifications of moving these earnings cross-border can be burdensome. We provide practical advice on moving your money efficiently and legally between entities and different jurisdictions. We can perform an E&P (earnings and profits) study to determine the appropriate treatment of a cross-border dividend payment and advise on options based on the level of your business’s E&P. We can consider risks of a payment being viewed as a deemed dividend and being re-characterized as such by the Internal Revenue Service (“IRS”). Intercompany service arrangements (discussed below) can be and in many cases are a basis for cross-border payments as well. New intercompany loans and repayment of principal and interest on existing loans are also good mechanism to consider.
Tax Disputes
- Tax Controversy
- U.S. Federal, State and Local Tax
- Managing Your Tax Risk
- Mini Due Diligence
- IRS Audit Defense …
Tax Controversy
Tax audits, examinations and even just informational requests and inquiries can put a lot of stress on your team. We have the knowledge and expertise to jump in and assist when these stressful events are thrust upon you. We will help support and substantiate your tax positions and will work hard to arrive at the best possible result. With tax authorities under pressure to collect more tax revenue around the world, the trend over the last few years has been for more examinations and audits, and often more aggressive ones too. Transfer pricing enforcement is also on the rise, and we can assist you by acting pro-actively to anticipate an upcoming audit, as well as by representing you on audit or Appeals and protecting your interests.