Specialist support for the cross-border problems that sit outside the range of a generalist practice—from US information return compliance and intercompany pricing to export incentives and defensible valuations.
WTP Advisors is a specialist international tax firm. We work on the cross-border problems that sit outside the range of a generalist practice: US information return compliance, intercompany pricing, export incentives, and the valuations that support both.
Our clients are US-parented groups with foreign operations, foreign-parented groups with US operations, and the CPA firms that serve them.
Reviewed by Brian Schwam, JD — Principal & National Managing Director of International Tax Services. Last reviewed: September 21, 2026.
Integrated support for the international tax lifecycle, with a clear path to the specialist service your matter requires.
Advisory across the US international regime—controlled foreign corporations and subpart F, the §951A net CFC tested income inclusion, the §250 deduction, foreign tax credits, treaty positions and permanent establishment risk.
For tax years beginning after December 31, 2025, structures modelled under the pre-2026 rules should be rechecked following material statutory changes.
Explore international taxPre-transaction work: entity selection and check-the-box classification, holding company jurisdiction analysis, treaty and limitation-on-benefits positions, repatriation planning and outbound transfer structuring under §367.
Compliance reports the decisions. Planning makes them.
Explore tax planningPreparation and defence of Forms 5471, 5472, 8858, 8865 and 926; Forms 8992 and 8993; foreign tax credit computations on Forms 1116 and 1118; and FinCEN Form 114.
Many international information returns carry penalties of $10,000 to $25,000 per form per year, whether or not tax is owed.
Explore tax compliancePlanning, documentation, implementation and controversy support under IRC §482 and the OECD Transfer Pricing Guidelines, including Master File, Local File, Country-by-Country reporting, benchmarking, APA and MAP support.
Led by Guy Sanschagrin, CPA/ABV, with a specialist team holding JD, LLM, PhD and CVA credentials.
Explore transfer pricing409A valuations, ASC 805 purchase price allocations, impairment testing, intellectual property valuation, gift and estate valuations, and support for §367(d) outbound intangible transfers and §482 intangible pricing.
Explore international valuationFeasibility, formation, annual §994 commission calculations, Form 1120-IC-DISC and Form 8404 compliance, and audit defence for qualifying US exporters.
We calculate commissions transaction by transaction through our ExPortal platform rather than relying on product-line grouping.
Explore IC-DISCSpecialist international tax capacity for CPA firms without the cost of building a department. The client relationship stays with the CPA firm; WTP Advisors supplies the specialist work.
Explore CPA firm collaborationOur technology helps specialists manage data-intensive calculations and documentation with consistency and control.
We collaborate with CPA firms that need international tax capability without building it internally. Your firm remains the trusted advisor and owns the relationship; we provide the focused technical work.
Learn how CPA firm collaboration works →Connect with WTP Advisors for specialist international tax, transfer pricing, IC-DISC, valuation or CPA firm support.