International Tax Services
Providing Guidance for International Business Owners
Because today’s world has become increasingly mobile, many people choose to live, work and own property in several countries. Directed by partner Kate Fishers, Ferrell & Kelly’s International Tax Services division constantly stays abreast of the intricate laws that govern the international financial world. As a result, this ensures that our clients can transact business, live and work anywhere in the world with financial peace of mind.
Ferrell & Kelly CPAs:
- Provide U.S. tax advice on a wide range of cross-border transactions.
- Have extensive experience in restructuring U.S. and foreign legal entities. It is often possible to restructure in a manner that qualifies the transactions as non-taxable under the U.S. tax code.
- Work in conjunction with non-U.S. tax advisors from many countries.
- Advise businesses and individuals in minimizing their worldwide effective tax rate using a variety of techniques, which includes maximizing foreign tax credits, excluding certain foreign income, and deferring U.S. taxation to a future year.
- Advise clients who are in the process of creating, acquiring, reorganizing, or selling U.S. and/or foreign entities.
International Tax Services for Businesses
- International mergers & acquisitions
- Inbound and outbound business activity planning
- Export tax incentives
- Structuring of foreign investments (U.S. businesses with foreign operations/investments)
- Passive foreign investment corporations (PFIC)
- Global mobility (international employee assignment cost reduction)
- Subpart F and taxation of controlled foreign corporations
- Repatriation and foreign tax credit planning
- Foreign businesses with U.S. operations
- U.S. businesses with foreign operations
- Withholding for partnerships, individuals and corporations
- Withholding tax reduction/elimination
- Transfer pricing
- Earnings stripping
- Inversion rules
- Branch profits taxation
- Check-the-box analysis
International Tax Services for Individuals
- Pre-U.S. residency planning
- Foreign tax credit planning
- Foreign earned income exclusion
- Foreign assets and account reporting (Form 114 and Form 8938)
- Taxation of foreign investment in U.S. real estate (FIRPTA)
- Taxation of international pensions and annuities
- Treaty analysis
- Streamlined (foreign and domestic) offshore compliance
- OVDP (offshore voluntary disclosure program)
- Expatriate analysis/planning/reporting
- Non-resident aliens with U.S. activities
- Social security tax planning
- Estate tax planning
- Controlled foreign corporation reporting/planning
- Subpart F and Code Section 956 analysis
- U.S. citizens living and working abroad
- U.S. citizens with foreign assets and/or activities
- U.S. and non-U.S. entertainers and athletes with worldwide income
- Gifts from abroad
Ready for assistance with your international tax questions?
Contact Kate Fishers today at KFishers@FerrellKelly.com