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
Why Choose KBF International Tax?
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Additional Resources
The Real Cost of Getting Transfer Pricing Wrong: Five Categories of Exposure
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Transfer Pricing for CFOs and Tax Directors: A Compliance Guide for Cross-Border Expansion
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Section 250 After the OBBBA: What Corporations Need to Know
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How OBBBA’s New Section 163(j) Rules Affect CFC Group Elections
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Transfer Pricing Documentation: A Guide for Multinationals
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Remittance Transfer Excise Tax: What Businesses and Providers Need to Know
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