International Corporate Taxation

WTS assists US and foreign based companies structure, implement and maintain optimal tax structures for their global holdings, business assets and supply chains. Considerations include the location of tangible and intangible property, personnel, permanent establishment exposures, compliance burdens, treaty benefits, etc.  The general objective is to minimize an organization’s effective tax rate, without impeding business operations and the movement of capital.

Tax Treaty Benefits

The ability to claim benefits under a double tax tax treaty can significantly reduce the overall tax burden with transactions, loans, and corporate structures. Our professionals are experienced with multinational tax treaties. We provide advice and opinions regarding taxpayer qualification for benefits. WTS professionals have experience representing clients with the IRS in APA and Competent Authority matters. WTS can also assist in the completion of US tax forms and reporting of tax treaty matters.

Transfer Pricing

The US tax regulations contain detailed transfer pricing provisions. The provisions contain requirements and methodologies for specific types of international arrangements. Contemporaneous agreements and documentation is generally required. WTS transfer pricing professionals include senior economists who can develop and implement efficient solutions for clients in light of the various transfer pricing requirements applicable to a particular set of facts. Common projects include IP planning, inter-company service arrangements and contract manufacturing.  Transfer pricing is key to the development of an effective global tax structure.

Cross-border Financing

Financing multinational operations in an efficient manner can provide significant benefits. WTS assists clients structure the financing for their US and foreign operations in a tax efficient manner.

Contact:    Rick Gardner, CPA, MST    ▪    +1 617 367 0111    ▪