Astrov P.C. advises on U.S. and international tax including income, transactional, and tax controversy matters.
- For example—
- How will income be treated for U.S. tax purposes? How will it be sourced? Will it be treated as subpart F income and subject to current inclusion in the U.S.?
- Will proposed structure or employee activities result in income being subject to tax outside the U.S.? Will compensation mechanism be subject to withholding by another country? If so, is there relief under a tax treaty?
- Will payments made from the U.S. to a non-U.S. entity be subject to withholding?
- What direct or indirect taxes will arise as a result of the proposed transaction? Will indirect taxes such as VAT be recoverable without registration? Will direct taxes be creditable for purposes of the U.S. foreign tax credit? Are all direct and indirect taxes properly contemplated in economic models?
- For transactions with related parties, is the (transfer) pricing method appropriate? What documentation needs to be prepared and when?
- What contractual arrangements need to be entered into in order to minimize any adverse tax outcomes?
- Advising on tax-efficient ownership models for income producing assets intended to be used in multiple jurisdictions. A typical review would include determining what U.S. and non U.S. direct and indirect taxes may apply under various ownership structures, and then developing a tax plan in light of the various direct and indirect taxes, applicable treaty relationships and other relevant factors (e.g. business/commercial drivers, U.S. subpart F, check the box planning, foreign tax credit, etc.).
- Planning regarding maximizing deductibility (and minimizing withholding) of intercompany service charges and developing appropriate transfer pricing documentation for relevant jurisdictions.
Tax Considerations for California Companies Operating Abroad
Listen to radio interview with Harry-Todd Astrov of Astrov P.C. on the morning radio show, "Business for Breakfast".