Helping Navigate the Complex U.S. Tax System

MichaelSilver’s International tax consultants has served foreign companies and individuals entering the U.S. marketplace successfully delivering a comprehensive range of value-added tax planning and consulting and reporting services. Our membership in GMNI  allows us to access global tax resources and coordinate with local experts and advisors.

Range of Expertise

Tax Consulting – Foreign Companies Entering the U.S.

• The most tax favorable entity structure
• Analysis of U.S. Tax Treaties with applicable foreign countries to maximize tax benefits, both in the U.S .and abroad
• The optimal states in which to locate and conduct business
• Tax aspects of various agreements (i.e., operating and employment agreements)
• Structuring inter-company transactions to ensure proper compliance with transfer pricing rules in the U.S.
• Structuring inter-company transactions to maximize tax deductions
• Repatriation of profits to home country
• Controlled group (multiple U.S. entities) issues

U.S. Tax Compliance and Planning

• U.S. Subsidiaries of foreign parent companies
• Foreign companies directly operating in the U.S.
• Foreign national employees working in the U.S. for the U.S. branch or subsidiary
• Foreign subsidiaries of U.S. Companies
• Expatriate U.S. citizens working abroad
• Equalization agreements
• Multi-state income and sales tax issues to avoid unnecessary state tax penalties and costly state tax audits
• Back-up withholding tax issues and requirements
• Representing our clients throughout the tax audit process to minimize or eliminate additional tax liabilities that may result from such audits
• Assisting U.S. companies with implementation of IC-DISC structures to maximize U.S. tax savings from export of goods produced, in whole or in part, in the U.S.
• Foreign tax credit planning and related reporting requirements
• Assistance with the Foreign Account Tax Compliance Act (FATCA) compliance and reporting requirement
• Assistance with Financial Crimes Enforcement Network (FinCen), also known as the FBAR (Foreign Bank Account Reporting) compliance and reporting requirements