International Tax

Many organizations look for growth opportunities beyond our borders to remain competitive in today’s global marketplace. Individuals and businesses looking for investment opportunities abroad need to understand the tax issues and business risks associated with foreign investments. Similarly, foreign investment into the United States requires attention to tax planning and structuring. Global expansion brings opportunities and challenges. Careful attention is required to address the tax implications of international expansion. Whether you are dealing with the issues of an existing operation or new investment, our team of international tax advisors can help you address the outbound and inbound international tax issues that affect partnerships, individuals, trusts, and corporations. Our global reach is extended through our affiliation with Moore Global Network Limited, collectively known as Moore, an international network of over 260 accounting and consulting firms, with over 600 offices, in over 100 countries. This global reach, combined with the team at HCVT, helps ensure that you will have access to technical and industry knowledge required to compete in the today’s global marketplace.

Our international tax services include:

• International tax planning and compliance including tax planning considerations due to changes in international law resulting from the Tax Cuts and Jobs Act effective on 1/1/2018, and the CARES Act effective on 3/27/2020
• Anti-deferral regimes (commonly known as subpart F, GILTI and PFIC regimes) analysis
• Inbound tax planning for foreign investment/operations in the United States
• Cross-border financing
• Repatriation of funds analysis
• Foreign tax credit planning and reporting requirements
• Tax treaty planning
• Implementing and optimizing IC-DISC structures for U.S. exporters, including benefiting from the new Foreign Derived Intangible Income ("FDII") deduction
• Foreign Account Tax Compliance Act (FATCA) registration, analysis, implementation and compliance
• Expatriate tax returns preparation
• International mergers & acquisitions
• Reporting and withholding on payments to foreign persons, including FATCA withholding considerations

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