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.