With constant legislative, regulatory and judicial changes, companies operating across borders are challenged to follow and comprehend ever-changing developments. Similarly, globalization, economic realities, operational adjustments, and corporate mandates require tax departments to follow and comprehend internal initiatives. The combination of these equally important streams require tax departments to be agile, well-versed in internal and external developments, andable to deal with competing goals and interests. Understanding the tax impact on business operations and transactions in multiple jurisdictions is vital for a company’s success.
PricewaterhouseCoopers' International Tax Services (ITS) group has experience helping companies address their cross-border needs. We help multinational businesses achieve their business goals in a tax-efficient manner, both locally and globally. Our International Tax Services professionals assist companies with:
Staying abreast of developments within the international arena that may affect their business, both globally and locally
Formulating effective and tax-efficient cross-border strategies for both US and overseas investments
Managing their global structural tax rate
Responding to inquiries from regulatory authorities
How efficient is your company’s cross-border tax planning strategy?
US-based multinational corporations (MNC's) are faced with the complexities of different tax jurisdictions as they expand on a globally. To remain competitive, they need to examine the tax implications of their business strategy in each jurisdiction where they currently or plan to conduct business.
Opportunity: Driving tax-efficient US to foreign investments
Our US outbound tax planning services group is comprised of experienced professionals that focus on US investments into foreign markets. By drawing on this experience and taking into account the client’s specific business goals and objectives, our US outbound tax planning services group is able to customize and implement business-driven structures to meet the changing needs of US MNC's. The US outbound tax planning services group’s cross-border tax planning strategies focus on relevant business and tax issues, including:
Debt restructuring
Foreign tax credits management
Partnership planning
Foreign loss planning
Maintaining US deferral
Financing
Redeployment of cash
How is your company responding to changing business needs in this global economy?
As a result of the globalization of business, the US continues to experience substantial inflow of foreign investments. However, US tax law has a profound effect on foreign-owned US companies—taxing its residents, including the US subsidiaries of foreign-based MNC's, on their income from all sources. The complexities and far-reaching aspects of the US tax system, coupled with the relatively high US corporate income tax rate, have forced foreign MNC's to look for opportunities to efficiently manage their US businesses while still ensuring that their structural tax rate remains competitive
Opportunity: Managing business and tax strategies to remain competitive
The interaction between US and foreign tax regimes may provide opportunities for foreign-based MNC's to reduce taxes on a worldwide basis. Our inbound US tax planning services group is a team of experienced tax professionals who focus on cross-border tax planning to help foreign-based MNC's efficiently manage their US operations and structural tax rate. A variety of strategies have been identified, developed, implemented, and documented to help foreign MNC's meet their business needs while maintaining a competitive structural tax rate.
Inbound Washington tax services
To assist non-US companies with US operations in understanding emerging US tax issues, our Washington National Tax Services (WNTS) group offers the inbound Washington tax service. This retainer-based service keeps the US subsidiary and foreign parent company informed of the latest US legislative, regulatory, and planning developments that impact US inbound companies. This service is tailored to the US inbound company's specific industry, facts and issues.
How efficient is your current global structure?
Companies that undergo operational or structural change should be aware of any resulting tax costs and their potential effect on corporate earnings. Similarly, as companies evolve and grow they may find that their tax position is no longer aligned with their business operations and strategic objectives, and that their current operating structure is inefficient from a US tax perspective. They may need to revisit their operational structure, streamlining their operations, revising their geographic footprint, and realigning their operations to coincide with their core competencies and expectations for growth.
Opportunity: Creating the right structure for your company
PricewaterhouseCoopers’ global structure alignment services group can help companies align their tax and operational structures by exploring and analyzing the complexities of economic transfers, deferral structuring, jurisdictional planning, operational infrastructure, and business support issues. By examining key attributes such as functions, risks, and assets, a company may achieve an alignment which reflects its operating model and corporate vision, while limiting its tax cost. Undergoing a business-driven tax-efficient operational change, may help companies to achieve global tax savings or reduce the risk of unfavorable tax treatment, adding bottom-line value to the company.
Is your company contemplating undergoing a merger or a reorganization or considering making an acquisition or disposition of a business unit?
A company undergoing a strategic transition (e.g. merger, acquisition, reorganization, divestiture, etc.) risks losing value and control. The chaos surrounding the transition often impedes a company’s ability to simultaneously focus on maintaining current operations, realizing valuable deal synergies, and achieving timely integration. Without a clear and comprehensive approach and the resources to achieve these strategic priorities, the company could miss unique opportunities, hinder transition efforts, and create unnecessary and potentially substantial risks.
Opportunity: Managing the transition to realize deal synergies
PricewaterhouseCoopers’ post deal services group can assist in identifying and analyzing the potential tax effects of a strategic transition during the planning and implementation stages of a deal, thereby providing the client with the opportunity to focus on the business opportunities, barriers, and risks associated with the transition. Analysis of the business transaction and the company’s business strategy should allow us to consider and offer suggestions to improve the company’s tax positions, create long-term efficiencies and tax cost savings. In addition, through our assistance we may be able to help the company manage the risk of value leakage from process disruption to current operations.
Exponential growth in business complexity and new regulatory demands for certainty have driven the quantitative analysis of taxes into the "C" suite. The tax department must respond to CFO/CEO inquiries quickly and precisely, and be ready to provide the cash tax and financial statement impacts of decisions and anticipate possible "what if" scenarios. Many tax department leaders are finding that traditional in-house tools and skills cannot keep up with the sophistication and precision that are demanded.
Opportunity: Navigate with foresight
For over 12 years, PricewaterhouseCoopers' ITS quantitative solutions (QS) team has come to the aid of Fortune 500 tax departments in situations such as these. QS builds on our client's knowns to drive the quantitative analysis of their unknowns — informing tomorrow's decisions today. Contact one of our specialists the next time you need to analyze:
Tax reform (e.g., Rangel)
Proposed regulatory guidance (e.g., Section 987)
Tax elections (e.g., CTB)
Tax attributes (e.g., FTCs)
Acquisitions / dispositions (e.g., 1248)
Where can you go for in-country intelligence and insight?
For US MNC's, keeping abreast of the legislative and regulatory changes in all jurisdictions where they operate is difficult enough; understanding how policy is formulated, which way the political winds are blowing, and what trends are on the horizon in each jurisdiction is nearly impossible. For those companies who need in-depth country intelligence and access, the international desks can provide critical insight and assistance.
Comprised of over 70 tax professionals from 45 countries, the international desk teams provide knowledge on individual country issues as well as planning and advice on pan-regional trends and developments. Clients can gain advice on such topics as the cross-border aspects of corporate restructuring, acquisition and divestiture planning, holding company strategies, financing arrangements, global supply chain and intellectual property planning, and foreign tax credits, all from the local country point of view.
Locate a country-specific tax specialist in three territories:
