International Tax

Navigating Global Tax with Confidence and Foresight

Cross-border commercial and investment activities offer immense growth potential and significant opportunities for many businesses and investors. This reward potential comes with significant complexity, risks, and traps for the unguided.

Whether your business seeks to explore the initial phases of international expansion or has already developed an international footprint, innovative and customized global tax planning is essential to ensuring future success and managing financial and reputational risks

KBF’s International Tax and Transfer Pricing team guides businesses and investors in expanding across borders while managing tax risk, reducing complexity, and maximizing opportunities. Whether you are investing abroad (Outbound) or entering the US market (Inbound), our team of specialists deliver strategies that align with your global business and investment objectives.

Our International Tax Services Include

Outbound Tax Services

Assisting US-based companies and investors to successfully structure and manage international operations.

Cross-Border Structuring, Planning & Transactions

Entity structuring and jurisdiction selection
Tax-efficient financing strategies
Global intangible low-taxed income (GILTI) / Net CFC tested income (NCTI), Foreign-derived intangible / Deduction eligible income (FDII / FDDEI), and Base Erosion and Anti-Abuse Tax (BEAT) Analysis and Planning
Supply chain / IP tax optimization
Tax Treaty Analysis and Planning

Foreign Tax Credit, Repatriation, & Cash Management

Maximizing credits to reduce double taxation
Strategies for tax-efficient return and global redeployment of profits
Managing withholding taxes
Foreign E&P and basis computations, and foreign currency quantification under sections 987/988

International M&A Support

Due diligence support on global acquisitions/dispositions
Outbound acquisition structuring
Post-deal integration for tax efficiency

International tax and ASC 740 Analysis, Preparation, and Support

Analyze and prepare international tax areas of provisions to support audit and regulatory review
Preparation and review of international tax computations and forms

Inbound Tax Services

Guiding non-US companies and investors with tax-efficient entry and expansion into the U.S. market, and appropriate structuring for real estate and other investments.

US Inbound Structuring, Planning & Transactions

Optimal choice of entity for business / investment (i.e., corporation, pass-through, or branch)
Cross-border financing, capital structuring, and treasury management
US trade or business / permanent establishment risk assessment and treaty-based analysis and planning
US real estate investment structuring and disposition planning
Treaty-based planning to reduce withholding taxes

Withholding and Branch level taxes

Reducing cash leakage on inbound transactions via treaty or statute
Analyzing and computing branch-level taxes
Inbound debt financing computations under US regulations 1.882-5

US Inbound M&A Support

Due diligence support on US acquisitions/dispositions
Inbound acquisition structuring - Post-deal integration for tax efficiency

International tax and ASC 740 Analysis, Preparation, and Support

Analyze and prepare international tax areas of provisions to support audit and regulatory review
Preparation and review of international tax computations and forms

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