BeachFleischman CPAs is an Arizona-based firm. We can serve clients remotely throughout Wisconsin and we're ready to assist you in your international tax needs. The international tax environment is an area of continued scrutiny and focus by the taxing authorities. From a tax compliance standpoint, there are many different forms that apply when doing business or investing abroad. These compliance requirements apply to both U.S. entities and U.S. individual taxpayers and failure to comply may result in substantial penalties. There are different rules with regards to recognizing income from foreign activities. Care should be taken with structuring transactions to ensure such is done so in the most tax-efficient manner and maximizing foreign tax credits.
Inbound and Outbound Activities
Outbound international activities:- U.S. individuals doing business or investing abroad
- U.S. corporations expanding operations overseas, via a foreign subsidiary or branch.
- Outbound cross-border transactions; income tax treaty interpretation.
- Foreign corporations coming to the U.S. to expand operations, via U.S. subsidiary or branch to the foreign entity.
- Foreigners coming to the U.S. to invest in U.S. businesses, U.S. real estate, or U.S. securities.
How we help
- Assisting clients with structuring cross-border transactions in the most tax-efficient manner.
- Assist foreigners that come to the U.S. to conduct business or invest in U.S. assets.
- Addressing the complexities with the different tax forms that are to be filed when doing business abroad or when certain assets are held abroad.
Wisconsin Exports, Jobs, and Foreign Investment
Wisconsin's Top 5 Export Markets
Wisconsin Depends on World Markets
Exports from Wisconsin helped contribute to the $2.21 trillion of U.S. goods and services exports in 2016.
Jobs supported by Wisconsin goods exports
Exports Support Jobs
111,075 U.S. jobs were supported by goods exports from Wisconsin in 2016. 93% of these jobs were supported by manufactured goods exports.
Wisconsin Employment in Foreign-Owned Companies
Foreign Investment & Jobs in Wisconsin
In 2015, foreign-owned companies employed 93,000 Wisconsin workers.
Source: Office of Trade and Economic Analysis, International Trade Administration, U.S. Department of Commerce.
Our International Tax Services
Passive Foreign Investment Company (PFIC)
A foreign corporation will fall under the Passive Foreign Investment Company rules if it meets either the Income test or the Asset Test. Due to these definitions, almost every foreign mutual fund will meet these requirements and will fall under the Passive Foreign Investment Company regime. When opening foreign securities accounts, it's important to know what type of investments will be made and whether they may be considered PFICs.
Foreign Bank Account Reporting (FBAR)
This is an area that can be fairly complex if U.S. taxpayers have financial accounts in foreign countries that are not the typical bank accounts. These requirements also extend to majority owners of U.S. entities that have signature authority or ownership of foreign accounts.
IC-DISC
Now that there is certainty as to the preferential taxation of qualified dividends, IC-DISC continues to be a great incentive for U.S. companies with significant export activity.
International Tax Structuring
We team up with foreign attorneys and accountants to come up with the best possible structure considering tax issues in both countries. In Mexico, we have an extensive network of legal and accounting contacts in different parts of the country with different areas of expertise, aside from LEA.
Mexico/U.S. Cross-Border Tax
We work with many U.S. companies and individuals that do business overseas, primarily Mexico and other Latin American countries. We team up with advisors in the foreign countries to provide the best possible support. We represent many Mexican families doing business in the U.S., many which include family members that are dual citizens of the U.S. and Mexico, that are obligated to fully comply with tax obligations that apply to residents of both countries.
Voluntary Disclosure Initiative
We assist U.S. citizens that have not been in full compliance with reporting offshore activity and have experience in getting them through the VDI program.
Foreign Interest in Real Property Tax Act (FIRPTA)
We have extensive knowledge in navigating the requirements FIRPTA. Our international tax team has helped foreign investors with countless transactions subject to FIRPTA for sales of real estate both in Wisconsin and nationally.
