WTS directly assists US and foreign based companies plan and implement optimal structures for the development and expansion of US operations and cross border opportunities. Considerations include the location of personal, property, intangibles, state and local tax exposures, compliance and treaty matters and overall tax efficiency.
Tax Treaty Benefits
The ability to claim benefits under a tax treaty with the US can significantly reduce the overall tax burden with transactions, loans, and corporate structures. Our professionals are experienced with US tax treaties. We can provide advice and opinions regarding taxpayer qualification for benefits. WTS also has significant 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 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.
Structured 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.