Cross Border and International Tax Planning

The most effective international tax planning approach is based on your company’s specific circumstances and identifies opportunities that make sense from both a business and a tax perspective. Through our affiliation with Baker Tilly International, Collins Barrow and ParenteBeard have access to tax partners around the world who collaborate with our team to identify tax planning opportunities for your international operations that make business and tax sense. These opportunities include:

1. Tax-efficient cross-border financing arrangements designed to minimize global tax burdens.

   This is especially advantageous for foreign companies who lend to their US Subsidiaries or capitalize their U.S. subsidiaries because the restructuring allows parent companies to convert interest income into exempt dividends eligible for the participation exemption abroad.

2. Repatriation transactions designed to minimize U.S. withholding taxes.

   U.S. subsidiaries of foreign parent companies can repatriate dividends from the U.S. to any foreign country without incurring U.S. withholding tax.

3. Global restructurings designed to minimize foreign tax burdens.

   These transactions are designed and developed to lower the tax burden of foreign companies in their home country by restructuring the U.S. group.

4. US planning designed to efficiently transfer foreign operations to parent company.

   These transactions are designed to lower the U.S. tax burden on the transfer of lower tier foreign corporations to the foreign parent.

5. US planning designed to tax efficiently remit dividends to the foreign parent on a tax deductible basis.

   These transactions are proposed and designed to repatriate dividends to parent corporation on a tax deductible and withholding free basis.

6. Transfer pricing studies.

   These studies are proposed and designed to remit profits to foreign parents using transfer pricing technology to minimize U.S. tax burden.

To learn more about how Collins Barrow can maximize your Cross Border and International Tax Planning opportunities, contact your Collins Barrow advisor.