If you or your client have income or operations abroad, the potential obligations and burdens that accompany a global tax position can be far reaching. The bad news? The IRS is taking a hard look at the taxation of foreign dealings. The good news? alliantNational provides a full spectrum of tax services for both business and individual international tax clients.

alliantNational has years of experience helping clients safeguard in-bound-outbound investments with a tax efficient structure, developing and defending transfer pricing policies with precise documentation and resolving controversy or scrutiny regarding international tax obligations.

alliantNational’s team of tax professionals will use proactive, forward-thinking strategies to help minimize international tax and maximize available foreign tax credits. Our team can help you plan for intellectual property, support positions taken on tax returns, guide you through global effective tax-rate planning and foreign tax credit management.

The time to act is now, and alliantNational can help defend your interests with:

• Transfer Pricing Documentation and policies
• Risk and opportunity assessments
• Intellectual property valuations
• Cost allocation studies and cost-sharing arrangements
• BEPS, country-by-country reporting, consulting and compliance

There are many good reasons why an American company would spread its business, its assets, and its operations abroad. Companies that have international clients may want to build up operations in the areas where their clients are. Companies may be importing supplies and raw materials and they may want to move operations closer to the source of these materials to reduce overhead. To encourage foreign businesses to set up shop, many countries offer favorable tax incentives for companies that are willing to bring in business.

American companies that derive income from abroad do incur tax liabilities here in the states and international tax concerns can be extremely complicated. It can be confusing getting a handle on the tax implications when multiple jurisdictions are involved. There are complex rules and ever changing regulations that need to be navigated and a mistake can be costly.

The IRS’s primary concern is always that it gets its share of income. The IRS does take certain factors relating to foreign-source income in calculating a company’s domestic liabilities. Some of the factors that the IRS considers in calculating tax liability includes:

• Type of Entity
• Normal return on physical assets
• Income above the normal return (Global Intangible Low Tax Income)
• Income from passive assets
• Profit derived from US based intangible assets
• Taxes paid to foreign governments

The IRS is particularly wary of companies that are attempting to shift income in a foreign country so that they can reduce the amount of profit they have to report to the IRS. A lower tax base means a lower tax liability and the IRS will litigate to ensure it receives what it believes it is entitled to.

The IRS will penalize companies that do not report or disclose foreign accounts and assets. This includes the following penalty types:

• Civil Tax Fraud
• Failure to Pay
• Penalty for Failing to File Form 8938
• Penalty for Failing to File Form 3520
• Failure to File Report of Foreign Bank and Financial Accounts (FBAR)

If you or your client wants to protect their CIC, the time to become compliant is now.

alliantNational’s team of experts helps with:

• Risk Pool and UTP Review
• FIN 48 Analyses
• Review and Preparation of Concern Areas
• Review and Analysis of Foreign Bank Report Filings
• Substantiation and Documentation Assistance
• Substantiation and Documentation Assistance
• Compliance Review

Already under audit? alliantNational will help you or your client avoid consequences the IRS are making consistently more severe, including understatement and negligence penalties, as well as the potential unwinding of the captive formation and subsequent loss of benefits.

The time to act is now, and alliantNational can help defend your interests with:

• Audit Defense
• Substantiation and Documentation Assistance
• Risk Assessment of Your Captive 

Take advantage of a free consultation to see how our team of experts can help.