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Tax Implications of Offshore Corporate Ownership

Business today is often global in nature, and San Diego businesses must often be ready to integrate into the global community.  How do you structure your companies to do this?  What are the tax implications of offshore corporate ownership and investments?  The primary questions relate to moving the booking of income to a jurisdiction with the lowest tax rate(s) whenever possible.  If you can book a transaction in Ireland it might save you 6% or 10% or more in taxation when compared to booking the same revenue here in the United States.  However, moving goods and services between your international companies must be handled legally “at arms length.”  Transfer pricing issues create complex tax, accounting and legal issues for any international business.

The impact of approaching taxation utilizing a water’s edge election instead of a “unitary taxation” strategy requires careful planning, and expert advice from seasoned legal, tax and accounting professionals.  This is the greatest advantage our clients appreciate about Allen Barron.  These services are provided by a single source vendor who is able to provide an informed expert perspective from a much higher level when approaching important business decisions.  Often companies are required to have separate professionals to provide legal advice, international legal advice, tax analysis, accounting and bookkeeping.  Allen Barron’s professionals are able to integrate all of these services providing the advantage of economies of scale, as well as a much broader perspective when approaching complex international business issues.

What Foreign Corporate Ownership categories will you be required to consider as you approach US taxation and the completion of IRS form 5471?  FATCA has created substantial challenges for those who had structured business entities in an effort to sidestep US taxation or reduce their international tax burdens.  International tax agencies including the IRS as well as financial institutions and banks are sharing information providing greater insight into foreign transactions, bank accounts, business and financial activity.  You need a partner who can help you to comply with all foreign and domestic taxation requirements while maximizing the opportunity for international business profit.  How can you best position your corporate structure to reduce the tax implications of offshore corporate ownership while maximizing income and opportunity?  We invite you to contact the experienced international tax, legal and accounting professionals at Allen Barron for a free consultation at 866-631-3470.