Tax Planning Strategies
As the end of the year approaches, how well do you know your personal “tributary landscape”?
From changes in income to changes in family size; from the growth of capital gains to the potential impact of the alternative minimum tax; from the annual search for additional tax deductions and the proverbial “shoebox” of unorganized receipts, how well prepared you can have a direct impact on how you can participate in smart year-end fiscal planning.
A recent article in Forbes referred to charitable contributions as a way to participate in smarter fiscal planning. Donor-advised funds (DAF) are a tool that can meet your tax reduction needs in the following ways:
You can receive an immediate deduction of the income tax in the year in which you contribute to the fund advised by your donor. Since a DAF is administer by a public charity, contributions qualify immediately for maximum income tax benefits. The IRS does impose some limitations, depending on the adjusted gross income (AGI) of the donor:
Multinational corporations generally operate abroad through foreign subsidiaries that are mostly tax as independent corporate entities. This system of separate entities gives incentives to multinationals to change reported profits to their affiliates in low tax jurisdictions by underestimating sales to them and excessive price purchases.
For tax purposes, most governments require that firms use a “mutual independence” standard, setting prices for transactions within the corporate group (“transfer prices”) equal to the prices that would prevail if the transactions were between independent entities. However, there is ample scope for companies to manipulate transfer prices, especially for intangible assets, such as the company’s exclusive patents and for which there is no easily established market price.
Advice on compliance with tax obligations.
Over time, as societies evolve, so do their systems of laws, this in order to regulate behaviors and behaviors that societies adopt through their interaction with the advances and resources that are at their disposal.
Tax laws are not an exception to this behavior. Over time, they have evolved and adapted to the new business forms and trade mechanisms that people and entities have experienced in their development process.
Each time they become more complex to interpret and understand the logical meaning pursued by the application of new legal regulations. It is important to resort the help of qualified professionals, who have the level of understanding in the interpretation and application of the new tax laws.
While it is true that the diversity of standards related to tax obligations in the United States is endless, it is no less true that ignorance of these does not exempt it from compliance.
Sampling, Forecasting and Business Modeling
We offer solutions and professional advice for:
Our services range from conducting basic searches for comparable companies (“comp searches”) for benchmarking purposes too complex transfer pricing issues (e.g., ip migration, dispute resolution, restructuring, start-ups, etc.)
U.S. transfer pricing
Our services include the preparation of U.S. transfer pricing documentation as provisioned in §§ 482 and 1.6662-6 of the U.S. Treasury Regulations:
“Principal Documents” as stated in § 1.6662-6(d) intercompany transfer of tangible property (e.g., distribution, retail) intercompany services (e.g., management, procurement, financial, engineering, etc.) intercompany transfer of intangible property (e.g. royalty payments, cost sharing agreements)
Global documentation (OECD guidelines)
We prepare global documentation for North America, Latin America, Europe, Middle East and Africa, and Asia Pacific:
Ip migration issues
Whether your company’s intangible assets consist of software, know-how, pharmaceuticals, or a non-routine intangible, we can help:
Transfer Pricing now days is not just a matter of compliance. In the world of BEPS, tax authorities are seeking for transparency, substance, and coherence. Our solutions will provide you a value-add according to your company’s situation.
Planning / Consulting
All of our services take into consideration the fast-evolving world of BEPS and transfer pricing. we provide transfer pricing advice in connection with:
Business restructurings, including advice on supply chain
Special circumstances (e.g., start-ups, loss positions, mergers, acquisitions)
Transfer Pricing policies, intercompany entries, intercompany agreements
Tax authorities have agreed to share information about the taxpayer. we can provide you with Tax transparent documentation through:
Is the tax authority questioning your company’s transfer pricing issues? you are not alone!