There are a lot of questions around the practices made popular by Apple, Google and Microsoft regarding offshore entities and mergers and acquisitions in order to shift corporate taxation offshore to lower taxation jurisdictions. How can offshore strategies benefit small to mid-sized San Diego businesses who wish to reduce taxation while remaining in compliance with the IRS and international taxation laws and regulations? The experienced international business and tax attorneys at Allen Barron are uniquely positioned to advise our clients moving forward.
The first strategic decision comes down to the creation and registration of intellectual property. The second strategic decision relates to the entities deployed and the relationship of those entities. The third strategic decision relates to transfer pricing as these entities transfer goods and services between associated entities. The IRS and the US Treasury are reviewing many aspects of transfer pricing and the concept of “Inversion.” Inversion is best described by a merger or acquisition of a US company by an offshore corporation, and then a reorganization that transfers corporate equity, intellectual property and income offshore to jurisdictions with a lower corporate tax rate.
Allen Barron has unique strategies for small to mid-sized San Diego businesses who wish to leverage offshore manufacturing, licensing and distribution opportunities to reduce overall tax exposure and operational profitability. These decisions need to be carefully planned and executed. The structure of the companies themselves, the nature of corporate transactions and the location of intellectual property will have a significant impact on the level of taxation at each level of corporate operations. Our experienced business, tax and accounting professionals approach these challenges from a “single perspective” informed by multiple disciplines. Most companies have to turn to two or three outside firms to find the expertise available in the single source alternative: Allen Barron.
If you are involved in international business, or have been considering the option of mergers and acquisitions in order to shift corporate taxation offshore we invite you to contact us for a free consultation at 866-631-3470.
