Transfer Pricing

Cross-border business transactions with related parties have to be established following the internationally accepted arm’s-length-principle and must be documented in line with domestic tax rules. Only if transfer pricing is understood as a continuous process will the taxpayer be able to minimize the related tax risks in the long run without putting their business model – as a base of corporate success – into question.

Read more here: https://htj.tax/transfer-pricing-in-usa

We have significant experience assisting our clients with complicated, international tax issues. The following list represents some of the areas in which we have provided both planning and compliance services for our clients:

  • US shareholders of foreign corporations
  • US partners in foreign partnerships
  • US grantors and beneficiaries of foreign trusts
  • US shareholders of Passive Foreign Investment Companies (PFICS)
  • Reporting for Foreign Bank and Financial Accounts (FBARs)
  • Blocked income reporting for deferral of tax in currency restriction situations
  • Donations to foreign charities by US private foundations via expenditure responsibility grants
  • Income tax treaty analysis for various issues including determination of residency, re-sourcing of income to avoid double taxation, reduction or exemption of tax
  • Determination of residency for income tax purposes for foreign nationals including optimization of elections for first and last year of residency
  • Social Security tax implications to compensation of foreign nationals and US expatriates including application and analysis of Totalization agreements
  • Foreign tax credit optimization including analysis of paid versus accrued methods and maximizing foreign source income
  • Optimization for US expatriates including analysis of foreign tax credit versus foreign earned income exclusions
  • Reporting of foreign rental properties including proper depreciation methods and treatment of rental of principal residence
  • Reporting and planning for nonresidents with US investments or US effectively-connected income
  • State residency and domicile issues for foreign nationals and US expatriates
  • Reporting gifts and inheritances from nonresidents
  • Consulting to employers of international assignees relating to tax equalization policy development and application, tax planning for international assignments including coordination with tax advisors in local jurisdictions, compensation structuring, payroll reporting and employee education and tax return preparation
  • Determination of residency for US citizens in US possessions