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Doug Wright, JD, LLM
Partner, International Tax and Transfer Pricing

Overview

Rapid global business expansion and increased competitiveness has driven international tax considerations into the spotlight for many companies and their owners. At the same time, most companies face significant barriers to proper international tax planning to achieve optimum results in their global cash tax burden or worldwide effective tax rate. Companies are hindered by lack of internal expertise and resources, inaccessible or mismanaged global data, complex corporate structures, complicated transaction flows and rapidly changing tax rules – all of which have created an international tax environment that can be difficult, at best.

BPM’s International Tax Quantitative Services (ITQS) Group performs complex international tax computations and analyses to support strategic global tax planning, reduction of worldwide cash tax burdens, management of worldwide effective tax rates and risks, determination of optimum tax reporting positions and efficient preparation of reliable tax returns. Our ITQS Group includes former Big-4 and national firm ITQS practice leaders with extensive experience directing significant ITQS projects for Fortune 500 and other notable companies.

Using BPM’s proprietary ITQS software programs and data interface tools, our ITQS Group provides leading-edge quantitative analysis, support and solutions on a wide range of complex global international tax matters, including:

  • Structural tax rate - base case assessment and strategic planning
  • Effective tax rate - analysis, planning, and risk management
  •  Intellectual property - global IP exploitation alternatives, including IP migration 
  • Transfer pricing - analysis of alternative transfer pricing strategies 
  • BEPS - impact analysis, alternatives modeling, global compliance support 
  • U.S. international tax compliance 
  • Foreign tax credit - optimization, redeterminations, forecasting and planning
  • Expense apportionment - 861-8 and headquarters expense optimization
  • Overall Foreign Loss (OFL) and Dual Consolidated Loss (DCL) studies and planning
  • Subpart F - effective tax rate computation, analysis and planning
  • Earnings and profits (E&P) - computation, analysis and planning
  • Foreign tax pools - computation, analysis and planning for FTC, Subpart F, repatriation
  • Tax basis studies - computation of outside share basis and inside asset basis
  • Repatriation planning - alternative repatriation strategies
  • Cash management - global financing and treasury alternatives
  • “Check the box” - U.S. tax elections analysis and planning
  • International M&A - alternative M&A, joint venture and restructuring strategies 
  • Supply chain - business model alternatives and supply chain optimization

People

Doug Wright, JD, LLM
Partner, International Tax and Transfer Pricing
 
Lu Zhang
Director, International Tax

Contacts

Doug Wright, JD, LLM
Partner, International Tax and Transfer Pricing