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
Webinar | Global Growth Opportunities in a Changing Corporate Landscape
CCW/Crowe and KBF CPAs invite you to join us for this internationally-focused webinar to learn about the strategies we are seeing our clients employ as they seek to grow their revenue and expand their footprint in markets outside of the US. We will cover a range of topics, with a focus on the EMEA and APAC regions.
European Commission Appeals Apple’s Major “State Aid” Tax Victory
Earlier this summer, Apple won a $15 billion State Aid case related to its Irish operations. This decision was rendered by the EU’s lower court. In…
Supreme Court Denies Review of Tax Breaks for Big Tech Companies in Altera but the Controversy Continues
The Supreme Court denied a petition of certiorari in Altera v. Commissioner on June 22, 2020, a closely followed case from the Ninth Circuit concerning…
The Future of International Taxation: BEPS 2.0, DSTs, or What?
Even as regulatory guidance is still being issued by the U.S. Treasury, nearly 2-1/2 years after the enactment of sweeping changes to the international taxation…
Treasury Releases Final Section 385 Regulations without Substantive Changes to the 2016 Proposed Regulations.
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Companies Continue to Evaluate APB 23 Benefits After Tax Reform; Impact of COVID-19 Related Repatriations on the Indefinite Reinvestment Assertion
The general comprehensive rule for providing deferred taxes on book-tax basis differences under ASC 740-10 requires companies to record a deferred tax liability (DTL) for…
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