Services

Our focus is specifically on those areas of international taxation that have the on U.S.-based multinationals and exporters.

Our focus is specifically on those areas of international taxation that have the on U.S.-based multinationals and exporters.

Integrated International Tax

We offer a full range of international tax services with a strong emphasis on the specialized needs of U.S.-based multinational enterprises.
• 861-8 Analysis to determine FTC utilization, inclusive of the new GILTI and branch baskets.
• CFC Earnings Analysis/Foreign E&P Studies, including tested income, deemed tangible income return, Subpart F, GILTI, deemed paid foreign tax credits.
• Transfer Pricing Analysis, including global transfer pricing documentation, benchmarking, supply chain analysis, and BEPS country-by-country reporting.
• TCJA Transition Year Services, including optimizing Section 965 and DPAD and laying the groundwork for the future.

IC-DISC Export Incentive

We offer comprehensive IC-DISC services, including structuring complex IC-DISC entities post-tax reform.​
• Identification of qualified exports receipts, including products, services licenses.
• Structuring formation.
• Calculating maximum IC-DISC benefits, including the development of allocation and apportionment (861-8) methodology.
• Utilizing VantagePoint to optimize results using all of the available pricing methodologies.
• Implementation of no loss rules.
• Oversight of IC-DISC management services, including compliance with 60-day rule.
• Implement deferral strategies including factoring and producers loans.
• Government filing, including IRS form 1120 IC-DISC.

Our services involve a high degree of quantitative analysis supported by VantagePoint, our proprietary software platform.

Capabilities

Global Intangible Income:
GILTI & FDII

Now is the time to analyze, adjust and document your allocation and apportionment methodologies acting as the limiting factor of GILTI and FDII.

Foreign Earnings
& Profits

Determine foreign earnings and profits, subpart income, tested income, QBAI, GILTI and deemed paid foreign tax credits.

Foreign
Tax Credit

VantagePointTM handles the complex computations underlying the full utilization of foreign tax credits including the new GILTI and Branch Income baskets.

Transfer Pricing,
BEPS & BEAT

VantagePoint’s fully integrates the impact of intercompany transactions to support global transfer pricing documentation, including the BPS CbCR.

IC-DISC
Export Incentive

The IC-DISC survived tax reform and remains a significant U.S. income tax benefit for most exporters.

Global Tax
Analytics

Maximize the permanent tax savings provided by the domestic production activities deduction for 2005 through 2017 taxable years.

Resources & Events

We combine international tax expertise in conjunction with the most advanced, versatile, and powerful global tax software tool in the industry.

We focus specifically on those areas of international taxation that have the greatest impact on U.S.-based multinationals and exporters.

VantagePoint™ provides a centralized data hub, which helps companies manage their global tax position throughout the year.