International Services

A whole new level of complexities is added when you have business investments and connections in multiple jurisdictions.   The global business environment is swiftly becoming more complex and increasingly interlocked. We understand the international business community and the challenges it faces in entering the U.S., U.K., and other markets. We provide progressive, value-added structuring, consulting and planning services to middle-market and large foreign companies looking to invest in the United States and abroad. Additionally, we ensure your specific objectives are inherit within any recommended strategy and that you are in compliance with local taxing authorities while minimizing your tax and filing obligations. 

Services Include:

• Transfer pricing, planning, & compliance
• Advanced pricing agreements
• International tax compliance
• International tax treaty or withholding analysis and filing requirements
• Federal, state and local incentive and credit maximization
• International customs and duties planning and compliance
• Direct and indirect foreign tax credit analysis
• Foreign holding company strategies
• Cross-border mergers and acquisitions
• Coordination and preparation of U.S. federal, State and local income tax returns
• Structuring of foreign investments in the U.S. and U.K.
• Comprehensive tax planning
• Valuation services
• Corporate organization and restructuring for US operations
• International customs and duties planning and compliance
• Foreign earnings and profits analysis
• Extraterritorial income exclusion analysis
• Direct and indirect foreign tax credit analysis
• Domestic international sales corporation analysis
• Foreign holding company strategies
• Dividend repatriation policy
• Cross-border mergers and acquisitions

We understand that the tax situation for multi-national families and those on foreign assignment is often complicated and frustrating. The U.S. tax scheme of worldwide taxation is extremely complex and the international information reporting required with regard to foreign wealth structures and the underlying entities can be very provoking, especially as it relates to foreign trusts, foreign financial asset reporting and foreign financial account disclosures. It’s a mine field, particularly for those individuals from civil and Sharia law jurisdictions.

The U.S. tax system with regard to the foreign tax credits, income exclusions and the various tax treaties is also a difficult situation for those working on foreign assignment. At Prager Metis, our tax professionals will work with you and your family advisors to understand your unique situation and establish a comprehensive tax strategy suited to your specific circumstances. We will provide options and thoroughly explain each so you can make decisions that are most comfortable for you. 

Services Include:

• Multi-jurisdictional tax consulting, planning and tax compliance
• Comprehensive tax planning
• Foreign trust and civil law wealth structuring, planning and tax compliance
• Pre-immigration planning
• Expatriation planning and tax compliance
• Foreign tax credit and income exclusion planning
• Tax controversy representation
• Offshore voluntary disclosures
• Foreign Account Compliance Act implementation
• Expatriate consulting and tax compliance
• Real property investment structuring and planning
• Special purpose structures
• Trustee and individual Foreign Account Compliance Tax Act (FACTA) compliance

Expanding your operation to the U.S. or abroad can be both exciting and challenging. The tax situation varies greatly between countries. At Prager Metis our Partners and Directors have a vast knowledge and understanding of inbound and outbound regulations regarding specific countries. Our team is well versed in the regulations and customs of these countries and can help you navigate the complexities of foreign regulations and business practices. 

Countries Include, but are not limited to:

• France —  John Gosch
• Germany — John Gosch
• Israel — Lori Roth
• Italy — Andrea Fantozzi
• Turkey — John Barka

• Italian Services

Services Include:

• Royalty Audits
• Multi-jurisdiction tax planning, structuring and compliance
• Business Management
• Centralized Withholding Agreements

Services Include:

• Audits of private companies in the United States and international subsidiaries
• Audits of U.S. subsidiaries of foreign parents
• Audits of U.S. GAAP and IFRS financial statements

Transfer Pricing refers to the allocation of profits between related entities. Transfer pricing relates to numerous types of transactions including; performance of services between parties, loans between parties, sales of tangible property between parties, transfers of Intangible property between parties and lease of real or tangible personal property between parties. 

During recent years, transfer pricing has gained increasing attention from tax authorities all around the world.  Countries have passed or introduced legislation with detail requirements for taxpayers to justify and more importantly, document that their intercompany pricing is at arm’s length. This mitigates the ability of companies to shift income from high-tax jurisdictions to low-tax jurisdictions. 

At the recent G-20 conference last fall in Europe, Transfer Pricing was a visible topic.  As a result of the conference, the nations that were present all agreed that the documentation to support the Transfer Pricing between inter-company parties will be more scrutinized by local taxing authorities thus creating a greater burden on companies to provide even more documentation.    

Transfer pricing and the tax issues surrounding them are some of the most complex issues facing multinational companies today.  At Prager Metis we have an expertise in transfer pricing and can utilize our knowledge as an opportunity to optimize profits, increase cash flows and moderate taxes while satisfying local authorities requirements. 

Prager Metis’ team will work with you to develop transfer pricing policies that are defensible, flexible and in-line with your company's overall strategic tax plan and goals, so that you can focus on other operational business objectives.