Tax-Neutral
Target Structuring
After BEPS and the TCJA, international tax planning is no longer about offshore accounts. Multinational enterprises and global families now face Controlled Foreign Corporation (CFC) rules, GILTI inclusions, and anti-deferral regimes that have changed how the US taxes global income.
Our International Tax practice designs and maintains your global legal entity structure. We model Subpart F exposure, transfer pricing, and treaty-based withholding so your international operations are tax efficient and hold up under regulatory review.
How we deliver this service.
A rigorous, phase-driven process ensures nothing is missed and every position is defensible.
Global Footprint Audit
We review your current global entity structure (subsidiaries, PEs, branches) to identify where US tax is leaking.
Jurisdictional Analysis
Our team reviews the tax treaties and local laws of each operating jurisdiction to improve your intercompany flows.
Subpart F & GILTI Testing
We run earnings and profits (E&P) testing to model the effect of Subpart F and GILTI inclusions on your US filing.
Structural Modeling
We design alternative structures, including holding company tiers and 'blocker' entities, to reduce your global effective tax rate.
Implementation & Compliance
We coordinate with local counsel to implement the new structure and set up the required Form 5471/8865/8858 reporting.
Ongoing Governance
We maintain your basis and E&P records each year so the structure supports dividend planning and stands up to audit.
CFC Strategy
GILTI and Subpart F, managed year by year.
The US taxes 'Global Intangible Low-Taxed Income' (GILTI) annually, which removes much of the deferral that Controlled Foreign Corporations (CFCs) once offered. Elections such as the Section 962 election, under which an individual chooses to be taxed as a corporation, can substantially reduce the current US tax on foreign earnings.
We prepare the E&P reconciliations needed to report your CFC's activities accurately on Form 5471, and we track 'Previously Taxed Earnings and Profits' (PTEP) so that when you eventually bring cash to the US, you are not taxed on the same dollar twice.
CFC focus: Subpart F (Section 951), GILTI (Section 951A), PTEP tracking, and Section 962 individual tax elections.
Tailored for every client profile.
Holding Strategy
Holding companies, IP, and the global asset footprint.
Holding companies in treaty-favorable jurisdictions such as the UK, Luxembourg, or Singapore can serve as hubs for global expansion. Using 'check-the-box' elections (Form 8832), we can often treat foreign subsidiaries as disregarded entities for US tax purposes, which allows global losses to be consolidated and cash to move between subsidiaries tax-free.
We also work on the placement of intellectual property, structuring royalties and service fees to reduce withholding tax and preserve local deductions while staying within the US Subpart F foreign base company income rules.
Holding focus: 'Check-the-box' elections (Form 8832), treaty shopping restrictions (LOB rules), and foreign tax credit pooling.
Pricing Strategy
Defending the intercompany price.
The IRS and other tax authorities audit intercompany transactions closely. If your foreign subsidiary charges your US parent for services or IP, that price must be arm's-length under IRC § 482. Weak transfer pricing is a common trigger for large audit assessments and double taxation.
We prepare the benchmark testing and intercompany agreements needed to defend your cross-border pricing, including documentation of comparative profits and economic analysis that substantiates your global cash flows.
Pricing focus: Section 482 arm's-length standards, intercompany service agreements, and benchmark profit analysis.
Ready to review your global structure?
An outdated legal entity structure costs money every year it stays in place. Talk to us about a redesign.
Specific deliverables, precisely documented.
“International tax today is about durability, not deferral. We build global structures that move capital efficiently and hold up to IRS review.”
Technical clarifications.
Answers to the most frequently asked questions about how this service works in practice.
Global Intangible Low-Taxed Income (GILTI) is a US tax on the 'extra' earnings of your foreign company. Even if the money stays in the foreign bank account, the US may tax it annually. We use the high-tax exceptions where they apply to keep this down.
Form 8832 lets you choose how the US treats a foreign entity, as a corporation or as a disregarded entity/branch. It is a useful tool for consolidating global losses and simplifying your US tax filing.
If you have significant transactions between your US company and a related foreign company, a study is your only protection against substantial IRS penalties, which can reach 40% of the tax underpayment.
In the post-2017 tax environment, true deferral is rare. With the right structuring, using 'blocker' entities or individual elections, we can often defer the tax itself even when the income must be reported.
Subpart F income is usually passive income, such as interest or dividends, earned by your foreign company. The IRS taxes it directly to you whether or not it is distributed. We structure your company to avoid these triggers where possible.
Related services.
Two Tax Systems, One Team
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