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Overview

Foreign-based companies seeking to expand into the U.S. or increase existing U.S. operations or investments need specialized expertise to properly identify and address the myriad U.S. and foreign tax issues relevant to them, particularly in today’s rapidly evolving, increasingly complex U.S. tax and business environment. Our dedicated ITS professionals have the in-depth expertise and relevant experience with U.S. inbound tax planning to provide cost-effective, value-added assistance to foreign-based companies that are establishing or expanding their U.S. footprint.

Our ITS professionals work with foreign-based companies operating in all global industry and business sectors and geographic markets to identify, develop, implement and maintain a company-specific tax-effective U.S. expansion strategy and tactical game plan that facilitates and enhances their U.S. and global business and financial successes. Assisting them are hundreds of tax professionals who bring their “home country” expertise and knowledge in the more than 106 countries where the 220 member firms of BPM’s LEA global firm network operate.

Our ITS professionals help foreign-based companies identify, properly evaluate and balance all U.S. and foreign tax and related considerations relevant to U.S. expansion, including:

  • Optimum timing of U.S. investment or expansion
  • Choice of location(s) for U.S. activities
  • Choice and characterization of U.S. inbound activities
  • If and when a U.S. entity is necessary
  • Choice of U.S. entity: branch, subsidiary or hybrid entity
  • Choice of state for U.S. incorporation or organization 
  • Use of U.S./foreign joint ventures and partnerships
  • Use of U.S. employees versus contractors
  • U.S. inpatriate assignments – structuring and tax compliance
  • Capitalization and financing of U.S. inbound operations
  • Cross-border use or transfer of intangibles
  • U.S. inbound transfer pricing strategy and documentation
  • Stewardship, management and back-office support
  • U.S. multi-state tax planning
  • U.S. income and withholding taxes – rates and reduction
  • U.S. double tax treaties – benefits and eligibility
  • U.S. Federal and state income tax compliance

Additional Services for U.S. Inbound Companies

For foreign companies with planned or existing U.S. operations, BPM also offers a comprehensive suite of other cost-effective services that are of value and practical benefit, including:

People

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