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The International Tax Services department at MMB is well resourced to handle a multitude of compliance and tax issues involving companies doing business on foreign soil, including:
Assistance to first-time exporters and those performing services outside of the United States:
a. Choice of entity and structuring the way business is carried on.
b. Where applicable, utilization of Tax Treaty provisions.
Assistance with international acquisitions, business sales, and reorganizations, including working through the complex rules of IRC Secs. 367, 368, 381, 382, 1248, and others.
Assistance to foreign companies with inbound US tax issues in connection with first-time or ongoing business operations.
Tax compliance work concerning foreign subsidiaries, foreign branches, US subsidiaries of foreign companies and US branches of foreign companies. This includes reporting for controlled foreign corporations, foreign branches, tracking earnings and profits pools, branch tax calculations, and foreign tax credit reporting.
Assistance with the determination of the amount of direct and indirect foreign tax credits available, foreign tax credit planning, and allocation of indirect expenses to maximize foreign tax credit utilization.
Assistance to foreign nationals investing in US real estate:
a. Choice of entity.
b. Compliance with the provisions of the Foreign Investors in Real Property
Tax Act.
c. Withholding tax compliance.
Tax compliance work for foreign nationals including planning for maximum tax benefits in the year of arrival and departure.
Tax planning and compliance work for US expatriates including maximizing utilization of the foreign-earned income and housing exclusions.
Assistance to those utilizing foreign trusts including proper tax compliance reporting.
Assistance with the provisions of income tax treaties and totalization agreements.
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