International Tax Services

Global Tax Planning & Structuring

When acquiring or establishing operations in new jurisdictions, the legal entity structure taxpayers choose will likely affect the global effective tax rate for the enterprise and its shareholders. With appropriate planning, a taxpayer may find the right structure can reduce the global effective tax rate. Forvis Mazars can help you identify an efficient structure based on your specific attributes and short-term and long-term business goals to help you move with momentum. To effectively advise our clients on these complex transactions, our tax professionals have proficient knowledge of corporate nonrecognition tax provisions, the partnership tax rules under Subchapter K, as well as the judicial doctrines such as step transaction, business purpose, and transitory ownership/existence. To the extent that there is a foreign entity or operations involved, we have the tailored intelligence of U.S. international tax rules and familiarity with foreign tax laws to help drive your business forward.

U.S. International Information & Reporting Services

Compliance with U.S. international information reporting requirements is a top priority for any multinational business. Forvis Mazars can help you navigate the complex rules for reporting international activities to help you meet filing obligations, avoiding costly penalties and unnecessary tax exposure.

Our tax technology suite offers web-based tools for data collection, collaboration, and knowledge sharing. Forvis Mazars can coordinate foreign tax compliance through Praxity, alliance firms, and Huddle—a leading cloud-based collaboration tool that allows us to share files and collaborate with you in a central online environment. Forvis Mazars understands the importance of working closely with clients and third-party tax professionals to share files and manage international tax projects.

Our membership in Praxity gives you the advantage of having access to firms in more than 100 countries with the same high standards as Forvis Mazars.

Domestic International Sales Corporations (DISC)

The use of a DISC may provide tax savings to U.S. exporters. In addition to helping establish and calculate the DISC commission under available pricing methods, Forvis Mazars can assist in preparing accounting records and income tax returns and identifying qualified export receipts.

Tax Due Diligence for International Investments

If you are considering investing in a business with foreign operations, assessing the tax position of the target company can have a significant effect on its enterprise value or on the representations and warranties required to complete a deal. Forvis Mazars can help investors identify U.S. tax risks associated with making a foreign investment. Through our membership in Praxity, we have access to tax professionals in more than 100 countries to help provide local country tax due diligence assistance.

Transfer Pricing

Transfer pricing refers to the intercompany pricing of goods, services, intangibles, or financing between related entities within an organization. It's one of the most complex and closely scrutinized areas of tax, involving many stakeholders including companies, fiscal authorities, regulators, and intergovernmental bodies. Transfer pricing is commonly thought of as a pressing tax issue for multinational enterprises (MNEs). However, transfer pricing rules also may apply to transactions between related entities in the same jurisdiction.

The rising volume of global trade within MNEs, along with evolving and more onerous documentation requirements, increased information exchange and audit activity, and the application of stricter penalties, has created a transfer pricing environment of unprecedented complexity. Companies must now comply with many transfer pricing rules and regulations, which has become time-intensive and costly. Accompanied by increased enforcement and public scrutiny, it’s no surprise that transfer pricing remains a leading tax and risk management issue for MNEs.

Our clients require a team of advisors who can assist them throughout the transfer pricing life cycle—from policy development and design through implementation, compliance, and dispute resolution. At Forvis Mazars, we work with our clients’ stakeholders to help develop and align transfer pricing strategy with our clients’ global business operations and wider commercial goals. We routinely provide transfer pricing services and solutions that consider people, processes, and technology to help meet compliance obligations, mitigate risk, and identify and deliver on opportunities to generate value so our clients can move with momentum.

Our transfer pricing solutions include:

• Planning

Whether entering new markets, restructuring operations, or reviewing transfer pricing policies, Forvis Mazars can help MNEs develop and achieve tax-efficient strategies through transfer pricing planning.

• Globally Coordinated Documentation

Most developed countries require transfer pricing documentation or have a transfer pricing disclosure requirement to substantiate an MNE’s intercompany transactions. Failure to maintain the proper documentation and/or filing requirements can often result in adjustments, penalties, and interest. Forvis Mazars works with clients on a globally coordinated basis to prepare the requisite documentation and/or filings to help mitigate these material tax risks.

• Transfer Pricing Controversy and Dispute Prevention/Resolution

In the event of an examination (transfer pricing audit), we help our clients manage the response to and negotiation with tax authorities to resolve the dispute. We also help our clients proactively manage transfer pricing risk to avoid controversy before it begins.

• Advance Pricing Agreements

MNEs can enter into advance agreements on their transfer pricing methodologies with at least one government body to obtain forward clearance and/or resolve past transfer pricing disputes. We help our clients engage with tax authorities and obtain these agreements by being proactive and delivering an Unmatched Client Experience over what is commonly a lengthy negotiation process.

• Intellectual Property Valuation

Valuation of intellectual property for tax purposes is necessary for business reorganizations and tax planning, such as cost-sharing arrangements. We understand how valuation of intellectual property for tax purposes can differ from traditional valuation approaches and have dedicated resources and skill sets to perform these valuations.

• Operational Transfer Pricing & Technology

We help clients fully operationalize their transfer pricing policies. This can include providing advice and guidance with respect to people, processes, and technology. Forvis Mazars also provides automation tools and technology solutions that can help with complex global services and cost allocations, profit splits, and other transfer pricing models.

• Value Chain Transformation 

Forvis Mazars has the consulting knowledge to help you solve complex supply chain management issues. We conduct in-depth value chain analysis to help improve global transfer pricing policies.

• Risk & Opportunity Assessments

Clients often ask us to perform objective reviews of their current global transfer pricing policies and practices. Our global team can provide locally tailored guidance and recommendations that can lead to more supportable policies.

Our transfer pricing professionals are located across the U.S. and worldwide, assisting clients of all sizes with transfer pricing planning, compliance, audit support, and other consulting needs. Our unique global network allows us to seamlessly provide knowledgeable transfer pricing services to our clients worldwide in over 90 countries and territories where we have presence. When necessary, we also work with our Praxity alliance firms to serve clients in less developed markets or where corroborative advice may be sought.

Global Mobility Services

Organizations need a global workforce and worldwide mobility to compete in the global marketplace. Crafting a detailed global mobility strategy takes time, teamwork, and careful thought. At Forvis Mazars, our global mobility services (GMS) practice helps companies plan, implement, and successfully manage international and state-to-state assignment programs. We work with a variety of multinational corporations, and the scale and scope of our knowledge spans the world, with our diversified, experienced, and passionate team working closely with clients to provide personal service on a global scale.

Inbound Services

Several issues can arise as foreign organizations move goods, services, and production to the U.S. Forvis Mazars can assist your multinational organization with tax planning for inbound operations focused on performance from strategy to execution.

Quantitative Services

Our international tax team can help you unlock your full potential with the following quantitative services: 

• Earnings and Profits Analysis
• Expense Allocation and Apportionment for Foreign Tax Credits
• Sourcing of Income
• Transfer Pricing Analysis
• IC-DISC Commission Computation on Varied Approaches
• Measuring Impact of Foreign Currency on Monetary Transactions
• Deemed Dividend Computations (Subpart F & Section 956)
• Computation of GILTI Tested Income
• Base Erosion and Anti-Abuse Tax (BEAT) Analysis and Related Computations
• Measuring Foreign-Derived Deduction Eligible Income