We combine expert tax analysis with our proprietary software platform to deliver reliable results and sustained tax savings.

Integrated International Tax Services

We offer a full range of international tax services with a strong emphasis on the specialized needs of U.S.-based multinational enterprises. This involves a high degree of quantitative analysis supported by VantagePoint, our proprietary software platform.

Example projects include:

• 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.

We employ a comprehensive approach, first considering our client’s legal structure, global supply chain and historic tax attributes, and then offering practical solutions for process improvements, while maximizing tax savings.
The IC-DISC survived tax reform and remains a significant U.S. income tax benefit for most exporters.

IC-DISC

We offer comprehensive IC-DISC services, including structuring complex IC-DISC entities post-tax reform.

IC-DISC services include, but are not limited to:

• 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 Software

Unlike traditional compliance software, VantagePoint focuses primarily on global tax optimization, achieving superior overall results.