U.S. Reporting and Compliance
U.S. Reporting of International Activities
We provide assistance with tax compliance for international transactions, including preparation and documentation of required forms, such as Forms 5471, 8858, 8865, and 5472.
U.S. Withholding Tax Compliance
Our professionals can offer guidance on withholding tax requirements and compliance, including analysis of tax treaties and assistance with obtaining withholding tax exemptions.
Foreign Investment Compliance
Foreign Investment in Real Property Tax Act Compliance
We help you achieve compliance with the Foreign Investment in Real Property Tax Act (FIRPTA), which includes an analysis of FIRPTA withholding requirements and tax implications for foreign investors.
Foreign Bank Account and Foreign Financial Asset Reporting
Reporting requirements for foreign bank accounts and financial assets can be complex. Our professional offer guidance on these requirements, including preparation of the necessary forms and compliance with Foreign Account Tax Compliance Act (FATCA) rules.
Investment and Income Regulations
Passive Foreign Investment Company Determinations, Elections and Reporting
Cherry Bekaert has extensive experience providing analyses and advice on Passive Foreign Investment Company (PFIC) rules and requirements, including:
- Determining of PFIC status
- Filing of required forms
- Planning and implementing PFIC elections
Anti-Deferral Calculations
The International Tax Compliance team is skilled in giving analysis and advice on anti-deferral tax rules, including Subpart F, Global Intangible Low-Taxed Income (GILTI) and Section 956. We also assist with planning and implementation of tax-efficient structures and strategies.
Export and Tax Benefit Strategies
Export Benefits
Our services include planning and implementation of tax-efficient export structures to maximize export benefits and reduce tax liabilities. These structures may include Interest Charge Domestic International Sales Corporation (IC-DISC) and Foreign-Derived Intangible Income (FDII).
Calculation and Modeling of Tax Benefits
Cherry Bekaert’s international tax professionals are experienced in quantitative analysis and modeling of tax benefits and implications of various tax strategies and structures.
Business Structuring and Planning
Entity Selection
We offer assistance with:
- Entity selection of direct, pass-throughs or corporate business structures
- Tax planning, including guidance on foreign tax credits
- 962 elections
- Internal financing methods
Quantitative Analysis and Consulting
Quantitative Consulting
The International Tax Compliance team provides quantitative analysis and modeling of tax implications and benefits of various business transactions and strategies. Additionally, we offer guidance on complex tax issues, including:
- Foreign tax credit utilization
- Overall foreign loss (OFL) and overall domestic loss (ODL) studies
- Earnings and profits studies
- Foreign tax pool analysis
- Foreign currency gain or loss calculations under Section 987 and 988.
