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International Tax Capabilities

Plan design and implementation

An effective international plan starts with your organization's overall goals and strategies. First, we work to understand your business operations and processes by using a rapid, strategic assessment of your international tax posture via RSM’s proprietary international comprehensive opportunity review (iCOR) tool. Among other areas, iCOR addresses a company’s opportunities and risks associated with:

  • Base erosion and profit shifting (BEPS)
  • Cross-border employees
  • Earnings and profits and tax pool studies
  • Foreign tax credit maximization
  • Permanent establishment
  • Subpart F and cash repatriation strategies
  • Transfer pricing
  • Withholding taxes
Then, we can help you build an international tax strategy tailored to your company's needs. Many multinational companies have a tax design that has been ineffectively implemented or is out-of-date. Frequent tax law changes can render even a sound design incomplete or expose a company to unnecessary risks. We will work with you to continually adjust your corporate tax structure to keep you on target as tax laws and regulatory demands in your various jurisdictions evolve and as your operations change and grow.

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International tax structuring

Our tax professionals have positioned thousands of organizations to take advantage of available U.S. and foreign tax benefits. We take a collaborative approach, working with you to understand your current and long-term goals while developing a plan to help you attain them. We evaluate your unique situation by exploring several aspects of your operations, including:

  • Location – Are you in, or moving to, the ideal location? We take into account the interplay between U.S. tax rules and the rules applicable to foreign investors.
  • Financing – How are you financing your expansion? The financing structure you choose could have significant tax implications.
  • Profitability – What is the likelihood of losses? Many international expansions result in initial losses. We can help develop a plan to minimize the financial impact.
  • Investment – How and where will your profits be retained? There are myriad options that carry differing tax consequences, ranging from reinvesting in the entity to diverting to another foreign location. We will help you choose which is most beneficial for your business.
  • Taxability – What will the IRS and other foreign taxation authorities expect from your organization? We will project the U.S. and foreign tax consequences of your expected structure.

Even if you are not considering expansion at this time, we can show you the possible opportunities or challenges that may arise due to your current structure and tax position.

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Transfer pricing

Many foreign countries seek additional sources of revenue and have turned their attention to more aggressive auditing of transfer pricing. The IRS has broadened its focus on multinational companies, meaning the number of transfer pricing audits is likely to increase in the coming years. The risk for noncompliance with proper transfer price documentation has never been higher.

We have developed a 10-step process to analyze, evaluate and document the manner in which your company determines pricing for the products, services and intangibles (i.e. trademarks, patents, copyrights) transferred between related companies. Improper documentation can result in additional taxes, interest and penalties.

We work with you to develop and implement proper transfer pricing strategies to minimize your risk and tax exposure. Read more about our Transfer pricing services: Integrated planning for global growth

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Tax compliance

Tax laws affecting multinational companies are changing constantly, both at home and abroad. International tax compliance is a full-time job. Each country has its own specific tax rules and regulations. Our professionals are proactive in addressing possible tax compliance issues and helping you understand the potential impact they may have on your business. We also help ensure conformity to all international tax guidelines, so you are not exposed to any undue risk. With our deep experience and worldwide resources, we build, implement and monitor an advantageous and flexible international tax structure with your business objectives in mind.

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International Assignment Services

Companies with a global workforce often have questions and concerns regarding a wide range of tax, payroll and compensation issues. Our international assignment services group can support your internal tax and human resources teams at every stage-- from assignment inception to repatriation.

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International mergers and acquisitions

Tax planning is vital in any merger and acquisition, doubly so for international deals. Foreign transactions raise a variety of questions, but RSM's global reach and deep experience helping companies navigate international deals gives you a single resource to turn to for answers. From tax due diligence to strategies for minimizing the immediate tax ramifications of your deal to advice on structuring your new combined organization for global tax success, our seasoned international and mergers and acquisition professionals can help you at every phase of your deal, here in the U.S. and, through RSM International, anywhere in the world your business takes you. Practical tax advice through every phase of a transaction offers a more detailed overview of RSM's mergers and acquisitions tax capabilities.

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New legislation

What does new tax legislation mean for your company? Recent tax law changes, and the likelihood of further shifts in the U.S. approach to cross-border taxation, could significantly affect your tax strategy. Laws in countries around the world are constantly evolving as incentives and transfer pricing guidelines shift to reflect conditions in different jurisdictions. Our advisors can help you understand new, complicated U.S. and international tax laws and their impact on your company. We can also inform you of available opportunities for tax credits and savings and set expectations for future performance.

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Global reach

You can count on deep local resources around the world through our membership in RSM International. With 700 offices in more than 80 countries, RSM International delivers strong tax knowledge and capabilities to help build successful cross-border strategies that benefit your company and your stakeholders.

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UPCOMING RSM TAX EVENTS

IN-PERSON EVENT

2016 Fall tax summit series

ON DEMAND WEBCAST

Business growth: Workforce tax considerations

  • January 20, 2016