International Tax

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A globalized world is rich with opportunity, especially when you can maneuver through the tax laws and regulations that come with operating in multiple jurisdictions. Our international tax team works with multinational companies, like yours, to optimize your success and guide you every step of the way.

Our goal is to cultivate trust and long-lasting relationships with our customers around the globe by constantly challenging the limit within ourselves to bring the highest level of quality, creativity, and value to every interaction. We aim to make every day exemplary.

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Compliance and Reporting

  • Global Intangible Lox-taxed Income (GILTI)
  • Foreign Bank Account Reports (FBARs)
  • Repatriation of Earnings and Foreign Tax Credits
  • Reporting and Disclosure Rules

Cross-border Employment Consulting

  • Planning for Inbound and Outbound Executives

Mergers and Acquisitions

Managing strategic or financial mergers and acquisitions by providing guidance through time-tested methodology, transaction execution and industry contacts.

  • Due Diligence and on Expansion Opportunities
  • Planning for Asset Transfers Between U.S. and Foreign Countries

Planning and Tax Optimization

  • Choice of Entities
  • Permanent Establishment Rules
  • Foreign-Derived Intangible Income (FDII)
  • Interest Charge – Domestic International Sales Corporations (IC-DISC)
  • Strategies for Repatriating Income
  • Tax Treaty Application

Transfer Pricing

Navigate the requirements and risks associated with intercompany transactions.

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more insights

The FBAR penalty debate is far from overThe FBAR penalty debate is far from over

The FBAR penalty debate is far from over

Learn how the Supreme Court's Bittner v. U.S. ruling impacts FBAR penalties and the ongoing Bedrosian v. U.S. case. Explore the legal debate over willful vs. nonwillful violations and what it means for foreign account reporting

Article
July 11, 2023
Tax Court: IRS Had No Authority to Assess Penalties on Certain International Tax FilingsTax Court: IRS Had No Authority to Assess Penalties on Certain International Tax Filings

Tax Court: IRS Had No Authority to Assess Penalties on Certain International Tax Filings

April 28, 2023
U.S. Supreme Court rules against the IRS on critical FBAR issueU.S. Supreme Court rules against the IRS on critical FBAR issue

U.S. Supreme Court rules against the IRS on critical FBAR issue

Learn how the U.S. Supreme Court’s ruling in Bittner v. U.S. reduces penalties for non-willful FBAR violations. Discover key takeaways on foreign bank account reporting, compliance risks, and what this decision means for taxpayers facing Bank Secrecy Act penalties.

March 9, 2023
IRA’s EV tax credit sparks international discordIRA’s EV tax credit sparks international discord

IRA’s EV tax credit sparks international discord

Previously, the Inflation Reduction Act (IRA) of 2022 introduced an EV tax credit that sparked international debate. However, with the credit now abolished under the Trump administration, this historic analysis explores the global impact and controversy surrounding the policy when it was in effect

February 8, 2023
European Union will implement a global corporate minimum taxEuropean Union will implement a global corporate minimum tax

European Union will implement a global corporate minimum tax

Learn how the EU's adoption of the OECD's global tax deal establishes a 15% corporate minimum tax for large multinationals. Explore the impact of Pillar Two on global taxation, corporate strategy, and economic policy shifts.

January 12, 2023
Prepare for major changes to the foreign tax creditPrepare for major changes to the foreign tax credit

Prepare for major changes to the foreign tax credit

Learn how the IRS's final regulations on foreign tax credits impact multinational businesses. Explore key changes, including the new attribution requirement, creditability criteria, and compliance challenges for U.S. taxpayers with foreign income.

January 12, 2023

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An independent firm associated with Moore North America.

In today’s global marketplace, you need guidance on diverse issues in diverse markets. Elliott Davis offers our customers access to national and international resources through our association with Moore, one of the world’s largest CPA firm associations with resources in every major market around the globe. That means no matter where your business takes you, Elliott Davis has resources already there and available to assist your needs. More information is available on our International practice page.

Elliott Davis is an independent member firm of Moore North America (MNA). MNA is a regional member of Moore Global Network Limited (Moore Global). All the firms associated with MNA are independent entities, owned and managed in each location. Their membership in, or association with, MNA should not be construed as constituting or implying any partnership between them.

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