Global Tax Optimization

Global Tax Optimization is a multifaceted endeavor including both macro and micro tax analysis and planning.

It involves the analysis of several key service lines, including:

  • Structuring
  • Transfer Pricing
  • FTC Utilization
  • 861-8 Studies
  • Foreign E&P

MACRO: In the initial phase it is important to adopt the appropriate legal/tax structure, capitalization, debt placement, and aligning transfer pricing policies with supply chain requirements.  This phase is designed to provide a “good-enough” sustainable tax position, but further work is necessary to fully optimize the end result.

MICRO: Completing the optimization fine tunes the process by adopting appropriate tax accounting methodology, including foreign E&P and Treas. Reg. 1.861-8 allocation and apportionment methodologies.

Forte uses VantagePoint to model clients’ data to achieve the optimal final results.