International Tax

FDII rewards domestic companies taxed as C-corporations and US-domiciled C-corporation subsidiaries of foreign multinational businesses with an effective tax rate of 13.125%. The FDII tax reform imposes this rate on a portion of income derived abroad from the sale of goods, services property and royalties from licenses, patents and trademarks.

In contrast with FDII, the GILTI tax reform provision imposes a minimum effective tax rate of 10.5% on similar nonroutine portions of income and allows a foreign tax credit for only 80% of the foreign taxes paid to foreign jurisdictions. The combination of GILTI and FDII tax reform are intended to keep more intellectual property and profits in the US. The implications of these two provisions will require significant changes to financial reporting and accounting processes.

Deemed repatriation requires US shareholders (including individuals) of certain foreign corporations to pay US federal income tax based on the foreign corporation's undistributed earnings and profits. This one-time cumulative deemed repatriation of earnings and profits is taxed as if it were actually repatriated by the US shareholder as a dividend distribution. Although the media has associated this new rule with large multinational corporations, many individuals, trusts and businesses will need account for a one-time deemed repatriation on their 2017 tax returns.

Aprio's International Services team advises foreign companies moving to the US (and US companies moving abroad) Leverage our expertise and guidance to set up and structure your international business operations to achieve what's next.

International companies must continually seek greater efficiencies in the coordination of multi-country tax planning to remain competitive and profitable. Aprio's International Services team provides worldwide tax planning services with the goal of minimizing your worldwide tax rate by providing IC-DISC services, setting up IP holding companies, financing companies and restructuring worldwide operations.

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Transfer pricing has become the most significant tax challenge global businesses face. Minimize risk and tax dollars paid by letting us ensure that your intercompany transactions are structured correctly through a transfer pricing benchmark or study.

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Employees who work abroad face unique tax filing and payroll requirements that demand the coordination of tax compliance in foreign jurisdictions. We work with companies to develop policies and procedures for the international HR services they offer, and we are familiar with individual income tax filing and payroll requirements in jurisdictions around the world.

Get peace of mind that your financial statements are accurate and reported in the standard required by the countries where you do business. We perform audits in IFRS and other accounting standards and are experienced in converting financial statements from one accounting standard to another.

We can assist you in structuring cross-border M&A transactions. Looking to acquire another company overseas? We go beyond routine due diligence to provide an independent perspective on your transaction that identifies deal breaker issues and opportunities for higher ROI. Looking to sell? We can help you set the right prices and terms for your business. Our team will appraise your business' value, giving you the information edge to assess potential transactions.