For foreign taxpayers that are investing into the U.S. market, Accorp’s tax advisors will review the foreign ownership structure, the type of cross-border transactions and foreign owners’ investment goals. Our tax professionals will provide the following services:

1. Recommend the proper type of U.S. entity to fit the business goals
2. Prepare the U.S. forms necessary to comply with U.S. tax reporting requirements
3. Assist with the preparation of the transfer pricing documentation
4. Ensure, when it is time to distribute dividends, that the distributions are made in a tax-efficient manner, taking advantage of the beneficial tax rates of applicable double tax treaties
5. When applicable, prepare inbound activities guidelines to minimize the risks of creating a taxable U.S. PE

U.S. taxpayers that are expanding business operations outside of the United States can look to Accorp for help. Our tax professionals will evaluate your business model, existing financial position and goals going forward. Accorp’s tax advisors will provide the following services and solutions:

1. Optimize the usage of foreign tax credits to minimize or eliminate double taxation
2. Advise on the U.S. tax consequences of conducting overseas business in a foreign currency/li>
3. Assist U.S. shareholders who invest in controlled foreign corporations (CFCs) with structuring cross-border transactions in a manner that reduces the impact of the anti-deferral rules designed to accelerate the U.S. recognition of income earned overseas by the CFCs
4. Evaluate the availability and benefits of an Interest-Charge Domestic International Sales Corporation (IC-DISC)
5. Determine the proper allocation of income and expenses in intercompany transactions with foreign affiliates pursuant to the transfer pricing rules and assist with the preparation of the transfer pricing documentation
6. Utilize the tax treaty network among the U.S. and other foreign countries to minimize withholding tax rates on investment income and reduce the risks of creating taxable foreign permanent establishments (PEs)
7. Prepare proper documentation necessary to report foreign activities on US tax returns
8. Recommend the proper form of foreign entity to meet business and investment goals
9. Design the most tax-advantageous forms of acquisition, disposition or reorganization of foreign operations from both the U.S. and foreign tax perspectives

Accorp can assist companies with navigating through the myriad of tax planning and compliance matters related to international assignments for both U.S. employees heading overseas and foreign employees heading to the U.S.

1. For U.S. employees working overseas, Accorp can assess the availability of the Foreign Earned Income Exclusion under IRC §911 (“Exclusion”) and the claiming of Foreign Tax Credits under IRC §901 (“FTCs”), as well as the interaction of these two areas. Accorp can determine the best tax result for each employee and prepare U.S. and state income tax returns, as needed
2. Accorp can assess the U.S. and state tax residency status for foreign employees working in the U.S. and advise on the all-important pre-assignment planning matters involved. Accorp can prepare U.S. and state tax income tax returns, as needed, for foreign employees including Forms 1040, 1040DS and 1040NR, as applicable, address all required U.S. information reporting requirements, treaty-based return positions and other complications, as needed