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International Tax

International Tax is one of the most complex areas of taxation. Navigating the U.S. international tax rules requires both a strong technical understanding and practical experience dealing with both U.S. tax rules and foreign tax rules and how they interact with one another. This is why international tax planning is vital to the success of any international operation. To find out more about our international tax planning services please visit our International Tax Planning page.

Contact Us International Tax Planning

Additionally, as U.S. tax authorities are looking for more and more global transparency, it is essential to be able to meet all the U.S. international tax compliance obligations. You will want to work with someone who possesses both the skill and experience to successfully assist you with your U.S. international tax compliance. To find out more about our international tax compliance services please visit our international tax compliance .

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We provide services related to the following:

Outbound Investment

  • Calculation of Earnings & Profits
  • Foreign tax credit utilization
  • Subpart F inclusions
  • Tested income and GILTI inclusions
  • Pass-through taxation income inclusions
  • U.S. Inbound Investment
  • Structuring of inbound investments
  • U.S. reporting of inbound transactions
  • Withholding tax due diligence on cross-border payments
  • Foreign Tax Credit Utilization

International Tax Optimization

  • Expense apportionment(1.861-8)
  • Foreign source income maximization
  • OFL and ODL studies
  • International Tax Compliance
  • Foreign source income maximization
  • OFL and ODL studies
  • International Tax Compliance
  • Form 1116 and 1118

Cross Border Filings

  • Form 5471, including earnings and profits and tax pool computations
  • Form 8858 for foreign disregarded entities
  • Form 8865 for foreign partnerships
  • Form 926
  • W-8BEN-E for FATCA and treaty benefits Form 8992
  • Form 8883
  • Section 367 reporting
  • Section 987 branch remittance gain or loss computations

International Tax Compliance Services for You

If you’re looking for a firm with the knowledge and experience to help you navigate international tax rules, WTP Advisors is the firm for you. Over the years, we’ve had the privilege of working with companies of all entity types to help them maintain cross-border tax compliance, no matter the complexity. Our team brings a commitment to excellence to your corner that includes attention to detail and respectful interactions. Call our international tax advisors today for your consultation and take the first step toward global tax compliance!

Frequently Asked Questions

International tax refers to the set of rules and treaties governing cross-border income, transactions, and entities. It is crucial because it impacts profitability, compliance, and global competitiveness.

Tax treaties aim to prevent double taxation and tax evasion. They allocate taxing rights between countries and provide mechanisms for relief, often reducing withholding taxes on dividends, interest, and royalties.

Residence-based taxation taxes global income of residents, whereas source-based taxation taxes income earned within a country regardless of residency. Most countries use a hybrid system.

Risks include double taxation, penalties for non-compliance, excessive effective tax rates, and increased exposure to audits or disputes with tax authorities.

The Base Erosion and Profit Shifting (BEPS) framework introduces transparency, reporting requirements, and measures to ensure profits are taxed where economic activity occurs, significantly shaping tax planning strategies.

CFC rules prevent tax deferral by attributing income from foreign subsidiaries to the parent company in high-tax jurisdictions, ensuring tax neutrality.

DSTs target revenue from digital services within a jurisdiction, creating additional compliance burdens and potential double taxation issues for global tech-oriented businesses.

A foreign tax credit allows businesses to offset taxes paid to another country against domestic tax liabilities, preventing double taxation but subject to specific limitations.

The selection between a branch, subsidiary, partnership, or hybrid entity can drastically change tax treatment, liability, and repatriation of profits.

Strategies include treaty planning, transfer pricing alignment, tax-efficient supply chains, and leveraging jurisdictions with favorable regimes.