Haskell & White LLP’s International Tax Services

• Advice about Business Structure and Choice of Entity
• Classification of Business Entities and Trusts under U.S. Check-the-Box Rules
• Transactions involving Virtual Currency

To confidently meet your tax filing and compliance obligations in the U.S., our team knows how to make the right inquiries and take the needed steps to keep your business fully compliant.

Inbound

• Tax Advice to Withholding Agent and Foreign Persons
• Character and Source of Income Analysis
• U.S. Tax Filing for Foreign Beneficial Owners
• U.S. Withholding and Reporting on Payment of FDAP Income to Foreign Persons (Forms 1042/1042-S)
• Foreign Account Tax Compliance Act (FATCA)
• Foreign Investment in U.S. Real Property Tax Act (FIRPTA) Reporting for Nonresident Aliens and other Foreign Persons
• U.S. Income Tax Return of a Foreign Corporation (Form 1120)
• Foreign Corporation Protective U.S. Business Activity Filing
• U.S. Information Return of Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business (Form 5472)

Outbound

• Specified Foreign Financial Assets (Form 8938)
• Report of Foreign Bank and Financial Accounts (FBAR)
• U.S. Holding Company Structures and Consolidated Returns (Form 1120)
• Passive Foreign Investment Companies (PFICS)
• U.S. Information Return of Certain Foreign Corporations (Form 5471)
• Return of U.S. Persons with respect to Certain Foreign Partnerships (Form 8865), including Schedules K-2 and K-3 (Form 8858)
• Reporting for Outbound Transfer of Property, Stock or Securities to Foreign Corporation and Potential “Toll Charge”
• Gain Recognition Agreements (GRA)
• Shareholders’ Share of Certain International Items (Schedules K-2 and K-3 to Form 1120-S)
• U.S. Information Returns Reporting Ownership of and Transactions with Foreign Trusts (Forms 3520 and 3520-A)
• Delinquent U.S. International Tax and Information Returns and Reporting Penalties
• U.S. Tax Reporting and Advisory for Employees of Foreign Government or International Organizations

• State Tax Residency Analysis and Nexus Planning
• State Unitary Group Exposure Analysis and Advisory Services
• State Combined and Separate Return Filings
• Water’s-Edge Election

• Structure Acquisition of or Investment in U.S. Trade or Business
• Foreign Investment in U.S. Real Estate
• Foreign Investment in U.S. Real Property Tax Act (FIRPTA)
• Inbound Due Diligence for Taxable Asset Acquisitions, Tax-Free Stock Acquisitions, and Domestic and International Reorganizations
• Debt/Equity and Capital Stack Structuring
• Earnings Stripping
• Related Party Transactions
• Qualified Intermediary, Withholding Foreign Partnerships and Withholding Foreign Trust
• Disposition by Foreign Persons of U.S. Partnership Interests

• Expatriation of Individuals
• International Gift and Estate Tax Planning and Compliance
• Pre-Arrival / Post-Departure Planning
• Foreign Trusts and Estates Reporting and Compliance
• Foreign Trusts with a U.S. Owner
• U.S. Estate Tax Reporting for Nonresident Aliens

When your business enters new international markets, tax issues can significantly impact the value and ideal structure of corporate finance transactions, from mergers and acquisitions to strategic alliances, divestitures, and capital raising. Haskell & White will advise you on the tax implications of new markets, ensuring you take proactive steps that align with your business strategy.

• U.S. Export Incentives, including FDII and IC-DISC
• Structuring Operations in International Markets
• Assistance with Indirect Taxes including GST and VAT
• Subpart F Income, Global Intangible Low Tax Income (GILTI) and other Anti-Deferral Regimes
• Investment in U.S. Property
• Transfer of Property, Stock, or Securities to Foreign Corporation
• Recapture of Foreign Branch Losses
• Dual Consolidated Losses and Possible Triggering Events
• Repatriation Planning
• Taxation of Foreign Dividends and other Remittances
• Foreign Tax Credit
• Overall Foreign or Domestic Loss
• Certification of U.S. Tax Residency
• Currency Gains and Losses from Qualified Business Units

Haskell & White creates customized, comprehensive tax plans that strategically consider favorable treaty positions between the U.S. and other countries.

• Reduction of U.S. and International Withholding and Capital Gains Tax
• Nonresident Alien and Foreign Corporation Tax Treaty Exemptions
• Customized Planning to take advantage of Favorable Treaty Positions
• Treaty-Based Return Position Disclosure
• Certification of U.S. Tax Residency

We will help you evaluate and minimize risks from transfer pricing and develop reports documenting your process in compliance with all applicable regulations.

• Assess and Minimize Transfer-Pricing Risk
• Transfer Pricing Documentation Studies
• Advisory to U.S. Inbound Distributors

Haskell & White’s foreign tax credit planning experts help maximize allowable tax credits for all of your foreign tax payments.

• How Base Erosion and Profit Shifting (BEPS) could impact your business
• Country-by-Country Reporting
• U.S. Territory Taxpayers
• Foreign Income Tax and Withholding Tax Reduction
• Know-Your-Customer Rules

Our team provides clear guidelines customized to your business and employee compensation structure. This way, your HR leaders can communicate with staff in a timely manner, and answer questions accurately.

• Individual Taxpayer Identification Number (ITIN)
• Determining Alien Tax Status
• Taxation of Nonresident Aliens
• Structuring International Assignments
• Company and Employee Compensation Planning
• Hypothetical Tax Calculation
• Assistance to Human Resource (HR) Department
• Foreign Earned Income Exclusion
• Foreign Tax Credits
• Withholding – Nonresident Aliens
• Income Tax Withholding and Reporting for Persons Employed Abroad