alliantgroup provides a full spectrum of tax services for both business and individual international tax clients through our alliantNational Washington, D.C. office.
Economic globalization presents an array of international tax issues for U.S. individuals or businesses with income or operations abroad, or foreign persons with income or operations in the U.S. The potential obligations and burdens that accompany a global tax position include: safeguarding inbound-outbound investments with a taxefficient structure; developing and defending transfer pricing policies with precise documentation and resolving controversy or scrutiny regarding international tax.
INTERNATIONAL TAX PLANNING
MINIMIZING INTERNATIONAL TAX AND MAXIMIZING/SUBSTANTIATING FOREIGN TAX CREDITS
alliantgroup’s team of tax professionals will use proactive, forward-thinking strategies to implement a plan that meets your business needs while optimizing tax consequences. Our goal is to use your vision to ensure that our strategies help you be successful and anticipate your needs in the following areas:
- Global effective tax-rate planning
- Deferral strategies
- Repatriation that meets your needs
- Foreign tax credit management
- Planning for intellectual property
- Support for positions taken on tax returns
INTERPRETING U.S. TAX TREATIES AND PROVIDING OTHER ASSISTANCE
alliantgroup provides inbound and outbound clients with permanent establishment and treaty protection analysis to minimize double taxation and assist in the most efficient global structuring. Our experts provide advice to ensure clients avoid withholding issues and meet all necessary compliance standards.
The U.S.’s stance on cross-border taxation will likely continue to shift, and in light of recent legislative changes and ever-evolving global laws, your international tax strategy could be vulnerable. Our team can help you navigate the intricacies of new U.S. and international tax laws and the consequences they might have on your international activity.
Companies conducting cross-border international business are perhaps facing no bigger issue than transfer pricing scrutiny. Government examination of transfer pricing practices is an increasing reality for mid-market businesses.
TRANSFER PRICING ANALYSIS
A study of your transfer pricing practices will identify the ideal tax structure that best suits your cross-border dealings. In addition, a formal analysis will simplify your tax exposure management and expand your business opportunities. alliantNational will help to:
- Create transfer pricing documentation and a substantiation strategy to match your company needs
- Establish transfer pricing policies and cost-sharing strategies that are economically supportable
- Conduct risk and opportunity assessments
- Oversee organizational structuring (domestic groups)
- Perform intangible property valuations
- Execute sustainable tax planning with favorable tax-rate benefits
TRANSFER PRICING DOCUMENTATION
Substantiation requirements and strict penalties place companies without a clear strategy at significant risk. alliantNational will assist in:
- Transfer pricing documentation
- Advance pricing agreements and government interactions
- Cost allocation study
- Cost-sharing arrangements
- BEPS, country-by-country reporting, consulting and compliance
TRANSFER PRICING CONTROVERSY
The IRS is increasing its enforcement efforts, and transfer pricing audits are becoming more contentious. Support from knowledgeable counsel has never proved more valuable.
INTERNATIONAL TAX CONTROVERSY
alliantNational’s world–class team of former IRS executives, key congressional staffers, technical experts and experienced litigators brings unparalleled tax knowledge. Comprised of attorneys and tax experts with years of experience on both the private and government sides of the examination table, our clients can rest easy knowing they are receiving the absolute best representation in all tax matters.
INDIVIDUALS WITH FOREIGN ASSETS
alliantNational’s competence in assisting taxpayers and financial institutions with foreign account tax compliance and asset reporting is also unmatched. In addition to the aforementioned staff of world-class counsel and government insiders, some of whom ran the IRS offshore programs, all matters of international account tax compliance are overseen by our team of offshore financial experts, consisting of former IRS examiners who are positioned to help you:
- Understand the Offshore Voluntary Disclosure Program (OVDP)
- Comply with FBAR reporting requirements
- Fulfill your obligations in all matters of financial reporting and withholding
We have advised taxpayers worldwide in matters involving unreported foreign accounts and assets, the improper or incomplete filing of tax returns or FBAR returns and other diverse matters of offshore scrutiny.