International Taxation for US Businesses

Controlled Foreign Corporation (CFC) is a registered corporate entity which operates various jurisdictions/ countries other than/apart from the one where the owner(s) resides. CFC laws work in corollary with tax treaties providing how taxpayers report their foreign income.

There are several complications in tax filings and compliances for international income. For instance, identifying the type of income on the basis of its sources like Subpart-F income (passive income & specific kind of easily shiftable profits), income from royalties, the income representing a normal return from tangible assets, etc. Then on the basis of this identification, you also need to bifurcate which part of the profit is taxable and which is exempted.

To curb ill-practices of tax evasion and tax avoidance using accounting chicanery by the corporates, the Department of The Treasury and the Internal Revenue Services have very strict tax surveillance and scrutiny systems and the slightest mistake can land you in some serious legal trouble.

We have handled various complex tax issues, to list a few:

• Foreign Subsidiary Company Reporting (Form 5471, GILTI and 8865 reporting)
• Foreign Holding (Form 5472)
• Having assets abroad (FinCen 114, 8938)
• US Branch tax of a foreign company (1120F, 5471)
• Transfer Pricing Issues and Efficiency & Tax Optimization Planning (TP Study and Arms length pricing)
• Foreign Disregarded Reporting (Schedule C entities having a foreign owner)

We help you with international taxation, along with providing a range of other services to take full accountability as the virtual CFO to your business.