Marcum LLP
Tax & Business

International Taxation

Three People Meeting

Marcum LLP's International Tax Services Group assists companies that are expanding their operations internationally.

Whether that means a move or expansion into or out of the United States, for operations or personnel, expert advice is crucial. Our International Tax Services Group has the extensive expertise and the technical knowledge to assist in structuring transactions worldwide. The Firm works closely with our international affiliates to assist clients by minimizing their overall tax burden while coordinating tax planning and compliance services.

Our professional staff is augmented by our relationship with Leading Edge Alliance, an affiliation of leading regional public accounting firms in major cities throughout the world. In addition, Marcum offers extensive global resources as the exclusive U.S associated partner firm of ECOVIS International, an accounting and advisory network with members in 60 countries on six continents.

GET IN TOUCH
Contact one of Marcum's regional representatives.

ASK MARCUM

Related Services:      International Taxation   |   Certified Acceptance Agent   |   International Individual Mobility Services   |   Transfer Pricing

International Tax Planning Consulting Services

Our team provides professional tax planning and consulting services in connection with the following:

Businesses and Entities

  • Optimization of structures for foreign investment and business operations in the U.S.
  • Optimization of structures for U.S. investment and business operations outside of the U.S.
  • Structuring for cross-border acquisitions, sales and other exchanges.
  • Structuring for acquisition, operation and disposition of U.S. real estate.
  • Controlled foreign corporation issues.
  • Interest Charge Domestic International Sales Corporations (IC-DISCs).
  • Passive Foreign Investment Company issues (PFICs).

Individuals and Trusts

  • U.S. executives working and residing overseas.
  • Foreign executives working and residing in the U.S.
  • Tax issues for non-citizens immigrating to the U.S.
  • Tax issues for individuals considering expatriation from the U.S.
  • Gift, trust and estate considerations for non-citizens with U.S. based assets.
  • U.S. beneficiaries of foreign trusts.

Other Matters

  • Income tax treaties and totalization agreements.
  • Foreign tax credits.
  • Subpart F and other anti-avoidance rules.
  • Tax aspects of foreign currency exchange.
  • Matters related to payments of U.S. source income to foreign persons.

Transfer Pricing

Our team works with multinational companies to define, manage and plan for transfer pricing. Our services include the preparation of domestic and worldwide documentation designed to comply with local requirements, assistance with the alignment of tax planning objectives and business objectives, and assistance with the assessment and management of tax risk.

LEARN MORE

Outsourced International Tax Director Services for Companies and Global Families

Our team provides outsourced services to companies that can benefit from having a part-time international tax director.

The need may be short term, such as in the event of an acquisition or disposition that temporarily increases workload beyond what can be comfortably handled by internal resources, or due to the need for a temporary replacement of a resource that is on vacation or other type of leave. Alternatively, the need may be long term due to a regular and continuous need for a sophisticated resource to assist with periodic international tax issues, but where the need requires less than full-time attention.

Our professionals provide hands-on services to help companies focus on international tax planning opportunities and compliance matters. Additionally, we can assist global families with the management of U.S. based investments, U.S. trust matters and overall financial planning objectives to meet their respective needs.

Withholding Tax Services

Our team provides advice to companies and individuals regarding issues related to withholding and reporting compliance, including:

  • U.S. withholding and reporting for payments made to foreign persons.
  • Use of Qualified intermediaries.
  • Foreign withholding tax matters.
  • Application of income tax treaties to amounts subject to withholding at source.
  • Application of U.S. withholding rules to offshore withholding agents.
  • Backup withholding matters.
Withholding Tax Services
Expatriate and Impatriate Tax Services

Expatriate and Impatriate Tax Services

Our team provides tax planning and compliance services to U.S. executives on assignment overseas and their U.S. employers, as well as to foreign executives on assignment in the U.S., including:

  • Consultation to foreign nationals and U.S. citizens living abroad with the objective of providing solutions to minimize taxes worldwide, including through the application of income tax treaties and social security totalization agreements.
  • Preparation of U.S. income tax returns and other required filings for individuals with cross-border tax issues.
  • Consultation to companies with executives on overseas assignment (inbound/outbound), including assistance to human resource and payroll personnel.
  • Assistance with the calculation of gross-ups of foreign assignment allowances, tax equalization computations, and appropriate actual and theoretical withholdings.

U.S. Tax Compliance

Our team provides a wide variety of tax compliance and preparation services related to foreign and international tax reporting, including:

  • General compliance services for U.S. corporations and individuals with foreign based businesses and investments.
  • Preparation of and assistance with data gathering for U.S. international tax forms (1118, 5471, 8865, 8858, 5472, 1120-F).
  • Quantitative services related to U.S. international tax calculations (foreign tax credit, Subpart F, section 956, earnings and profits).
  • Accounting and tax preparation services for foreign nationals and foreign owned businesses.
  • Withholding tax returns for U.S. payers to foreign persons.
  • Assistance with U.S. individual tax identification numbers.
  • Income tax services for U.S. individuals with beneficial interests in foreign trusts.
  • Estate tax returns for nonresident aliens.

TAX REFORM INSIGHTS

Stay Informed about the Latest Developments in National Tax Reform

  VIEW TAX REFORM INSIGHTS
 
 

Related News

Bloomberg News quoted Mid-Atlantic Regional Tax Partner-in-Charge Edward Reitmeyer, in an article about the October 15 tax filing deadline, the first under the Tax Cuts & Jobs Act of 2017.


As Seen In

Bloomberg News quoted Mid-Atlantic Regional Tax Partner-in-Charge Edward Reitmeyer, in an article about the October 15 tax filing deadline, the first under the Tax Cuts & Jobs Act of 2017.

Ed Reitmeyer, the Mid-Atlantic regional partner-in-charge [of Tax Services] at accounting firm Marcum LLP, said he emailed his staff in late July and September to ....

ECOVIS Americas published an article by International Tax Co-Leader Douglas Nakajima, discussing the impact of the Tax Cuts & Jobs Act on the operations and tax structures of multinational companies.


As Seen In

ECOVIS Americas published an article by International Tax Co-Leader Douglas Nakajima, discussing the impact of the Tax Cuts & Jobs Act on the operations and tax structures of multinational companies.

TCJA was marketed to an eager U.S. audience as moving the U.S to a territorial tax system which typically would have taxed only U.S. sourced ....

ECOVIS published an article by International Tax Manager Ragini Subramanian, about new U.S. tax law governing cross-border transactions.


As Seen In

ECOVIS published an article by International Tax Manager Ragini Subramanian, about new U.S. tax law governing cross-border transactions.

With the growth in global technology, easy accessibility of data and information flow, and increased international trading, we can appreciate that cross-border business activity is ....

Form 5471 - Information Return with Respect to Certain Foreign Corporations


Tax Flash

Form 5471 - Information Return with Respect to Certain Foreign Corporations

Form 5471 is one of the most complex and complicated tax forms the IRS has ever created.

ECOVIS Americas published an article by International Tax Manager Ragini Subramanian, about considerations for a U.S. company considering establishing operations offshore.


As Seen In

ECOVIS Americas published an article by International Tax Manager Ragini Subramanian, about considerations for a U.S. company considering establishing operations offshore.

With the growth in global technology, easy accessibility of data and information flow, [and] increased international trading, we can appreciate that cross-border business activity is ....

ECOVIS Global published an article by International Tax Manager Ragini Subramanian, about taxation of foreign investors selling real property interests in the United States.


As Seen In

ECOVIS Global published an article by International Tax Manager Ragini Subramanian, about taxation of foreign investors selling real property interests in the United States.

Strong economies of many foreign jurisdictions have contributed to the increase in the purchase of real property interest by many foreign investors in the United ....

Proposed Regulations under Passive Foreign Investment Company Regime


Tax Flash - International Taxation

Proposed Regulations under Passive Foreign Investment Company Regime

The PFIC regime is a punitive tax regime established in 1986 with the purpose of denying the benefit of tax deferral to U.S. persons who ....

245A (Participation Exemption) Temporary Regulations Eliminating Deduction for Some Foreign Corporation Dividends to U.S. Taxpayers


Tax Flash - International Taxation

245A (Participation Exemption) Temporary Regulations Eliminating Deduction for Some Foreign Corporation Dividends to U.S. Taxpayers

The new participation exemption (245A) regulations eliminate the deduction for certain dividends received by U.S. taxpayers from foreign controlled corporations.

GILTI Final and Proposed Regulations


Tax Flash - International Taxation

GILTI Final and Proposed Regulations

On Friday, June 14, 2019, the Internal Revenue Service issued final regulations, as well as new proposed regulations, for the new anti-deferral regime known as ....

ECOVIS Americas published an article by Tax Director Debra Silverthorn on the tax treatment of a nonresidential alien.


As Seen In

ECOVIS Americas published an article by Tax Director Debra Silverthorn on the tax treatment of a nonresidential alien.

A foreign national who has neither a green card nor satisfies the Substantial Presence Test is considered to be a U.S. nonresident.

Pennsylvania Treatment of GILTI and FDII: Corporation Tax Bulletin 2019-02


Tax Flash - International Taxation

Pennsylvania Treatment of GILTI and FDII: Corporation Tax Bulletin 2019-02

On January 24, Pennsylvania’s Department of Revenue released Corporate Tax Bulletin 2019-02, addressing the Pennsylvania tax treatment of GILTI and FDII.

Accounting Today announced the availability of the 2018 Marcum Year-End Tax Guide.


As Seen In

Accounting Today announced the availability of the 2018 Marcum Year-End Tax Guide.

Marcum LLP released its 2018 Year-End Tax Guide on Wednesday, providing advice to taxpayers and tax professionals about how to handle the Tax Cuts and ....

Marcum LLP Releases 2018 Year-End Tax Guide: Reference Tool for Tax Planning


Press Release

Marcum LLP Releases 2018 Year-End Tax Guide: Reference Tool for Tax Planning

Marcum LLP today released its 2018 Year-End Tax Guide. This year's guide includes 17 chapters discussing how taxpayers are affected by the Tax Cuts & ....

Tax Notes consulted Partner Elizabeth Mullen for an article analyzing the transfer-pricing dispute between Coca-Cola and the IRS.


As Seen In

Tax Notes consulted Partner Elizabeth Mullen for an article analyzing the transfer-pricing dispute between Coca-Cola and the IRS.

Coca-Cola walked into the second quarter of 2018 unsure about how a new sugar tax in the United Kingdom would eat into its bottom line, ....

International accounting association ECOVIS published an article by Marcum's International Tax Group, about the new Foreign-Derived Intangible Income (FDII) Deduction, in its global newsletter.


As Seen In

International accounting association ECOVIS published an article by Marcum's International Tax Group, about the new Foreign-Derived Intangible Income (FDII) Deduction, in its global newsletter.

Internal Revenue Code Section 250 has been added to the Tax Cuts and Jobs Act of 2017, creating a new preferential tax rate for income ....

Three Marcum LLP Partners Honored in Inaugural Notable Women in Accounting & Consulting by Crain’s New York Business


Press Release

Three Marcum LLP Partners Honored in Inaugural Notable Women in Accounting & Consulting by Crain’s New York Business

Three tax partners in the New York City office of Marcum LLP were honored in the inaugural edition of Notable Women in Accounting and Consulting ....

Tracing of Interest Expense Related to Debt-Financed Distributions


Tax Compliance

Tracing of Interest Expense Related to Debt-Financed Distributions

When proceeds are received from a loan, there are various tax consequences depending on whether the borrower is the taxpayer or an entity owned by ....

The IRS Issues Proposed GILTI Regulations


Tax Flash - International Taxation

The IRS Issues Proposed GILTI Regulations

On September 13, 2018, the IRS issued proposed regulations concerning the Global Intangible Low-Taxed Income provisions enacted under section 951A as part of the Tax ....

Proposed Section 965 Regulations Related to Transition Tax


Tax Flash - International Taxation

Proposed Section 965 Regulations Related to Transition Tax

On Wednesday, August 1, 2018, the Internal Revenue Service issued proposed regulations under the repatriation tax provisions of Section 965 enacted as part of the ....

Tax Management International Journal published an article by Manager Ragini Subramanian on exit tax strategies.


As Seen In

Tax Management International Journal published an article by Manager Ragini Subramanian on exit tax strategies.

The U.S. Department of Treasury recently published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency during the third ....

The National Association of Tax Professionals, New York chapter, published an article by Tax Manager Ragini Subramanian, about the taxation of personal services income received by a non-U.S./foreign person from the U.S.


As Seen In

The National Association of Tax Professionals, New York chapter, published an article by Tax Manager Ragini Subramanian, about the taxation of personal services income received by a non-U.S./foreign person from the U.S.

This article is the second in the series of articles that discusses foreign-related issues - foreign information reporting, application for ITIN, foreign versus U.S. status, ....

IRS Grants Relief to Taxpayers in Connection with Certain Transition Tax Penalties


Tax Flash - International Taxation

IRS Grants Relief to Taxpayers in Connection with Certain Transition Tax Penalties

On June 4, 2018, the Internal Revenue Service released IR-2018-131, providing that it will waive certain penalties relating to the newly enacted transition tax assessed ....

2018 Gift and Estate Tax Changes under the Tax Cuts and Jobs Act: Transfer More Wealth Tax-Free


Tax Reform

2018 Gift and Estate Tax Changes under the Tax Cuts and Jobs Act: Transfer More Wealth Tax-Free

The Tax Cuts and Jobs Act (TCJA) of 2017 introduced a wide array of changes to most areas of the tax law beginning with the ....

Foreign-Derived Intangible Income


International Taxation

Foreign-Derived Intangible Income

Enacted as part of the 2017 Tax Cuts and Jobs Act, new Internal Revenue Code Section 250 creates a new tax deduction for income derived ....

Bloomberg BNA's Daily Tax Report published Part II of Tax Manager Ragini Subramanian's article on the complex requirements of expatriation.


As Seen In

Bloomberg BNA's Daily Tax Report published Part II of Tax Manager Ragini Subramanian's article on the complex requirements of expatriation.

In Part 2 of a two-part article, Ragini Subramanian of Marcum LLP walks through determining the value, type, and location of a taxpayer's assets on ....

Bloomberg BNA's Daily Tax Report published Part I of an article by Tax & Business Services Manager Ragini Subramanian about the intricacies of becoming an expatriate.


As Seen In

Bloomberg BNA's Daily Tax Report published Part I of an article by Tax & Business Services Manager Ragini Subramanian about the intricacies of becoming an expatriate.

In Part 1 of a two-part article, Ragini Subramanian of Marcum LLP analyzes factors to consider when contemplating expatriation, including whether the taxpayer is a ....

Farewell to the Offshore Voluntary Disclosure Program: The IRS Pulls the Plug


Tax Flash

Farewell to the Offshore Voluntary Disclosure Program: The IRS Pulls the Plug

In spite of its many iterations since 2009 and the 56,000 new taxpayers with their $11 billion added to Internal Revenue Service coffers, on September ....

IRS Issues Notice to Explain New Toll Tax


Tax Flash - International Taxation

IRS Issues Notice to Explain New Toll Tax

On March 13, 2018, the Internal Revenue Service issued additional guidance to help taxpayers meet their filing and payment requirements under the new Section 965 ....

Inc. magazine quoted Mid-Atlantic Regional Partner-in-Charge of Tax & Business Services Ed Reitmeyer in an article about errors in the new federal tax law that could cost taxpayers big money.


As Seen In

Inc. magazine quoted Mid-Atlantic Regional Partner-in-Charge of Tax & Business Services Ed Reitmeyer in an article about errors in the new federal tax law that could cost taxpayers big money.

Many entrepreneurs have celebrated President Trump's signature legislative achievement, the 2017 Tax Cuts and Jobs Act, for decreasing their annual tax bills.

Global Intangible Low Taxed Income: A Step Away from Territorial


Tax Flash - International Taxation

Global Intangible Low Taxed Income: A Step Away from Territorial

The new tax reform law has been widely touted by the media as transforming the U.S. into a territorial system of taxation as used by ....

The New York Times quoted national Tax Leader Joseph Perry in an article discussing the complexities and confusion created by the Tax Cuts & Jobs Act, and the likely battles yet to come in Congress.


As Seen In

The New York Times quoted national Tax Leader Joseph Perry in an article discussing the complexities and confusion created by the Tax Cuts & Jobs Act, and the likely battles yet to come in Congress.

Never mind that once in a generation tax bill that just passed last year. Congress is headed for years more of big fights over taxes, ....

The Impact of Tax Reform on Financial Accounting


Tax Flash - Tax Return Compliance

The Impact of Tax Reform on Financial Accounting

On December 22, 2017, the Tax Cuts and Jobs Act, was signed into law. The Act will have a significant impact on financial reporting issued ....

Long Island Business News wrote about the advice Marcum panelists gave to businesses considering restructuring as C-corps, during the Firm's recent tax reform seminar in Melville.


As Seen In

Long Island Business News wrote about the advice Marcum panelists gave to businesses considering restructuring as C-corps, during the Firm's recent tax reform seminar in Melville.

Much of the Marcum seminar focused on the taxation differences between C‐corps and pass‐through entities, which include partnerships, S‐corporations, limited liability companies and sole proprietorships.

New IRS Directives Issued for Transfer Pricing Examinations


Tax Flash - International Taxation

New IRS Directives Issued for Transfer Pricing Examinations

On January 12, 2018, the Large Business and International Division of the Internal Revenue Service issued five directives which provide instructions on how IRS agents ....

Bipartisan Budget Act of 2018


Tax Flash - Tax Return Compliance

Bipartisan Budget Act of 2018

The Bipartisan Budget Act of 2018, enacted last Friday, February 9, contains a number of tax breaks for both individuals and businesses. These include the ....

The Hartford Business Journal quoted Connecticut Tax Partner-in-Charge Brett McGrath, in an article about the impacts of the Tax Cuts & Jobs Act of 2017.


As Seen In

The Hartford Business Journal quoted Connecticut Tax Partner-in-Charge Brett McGrath, in an article about the impacts of the Tax Cuts & Jobs Act of 2017.

More than 30 years after digesting the last major federal tax overhaul, Connecticut accountants and legal advisers working to interpret the latest changes to the ....

CNBC quoted Tax Principal Michael D'Addio in an article about adjusting paycheck withholdings to comply with the new tax rates for individuals.


As Seen In

CNBC quoted Tax Principal Michael D'Addio in an article about adjusting paycheck withholdings to comply with the new tax rates for individuals.

In January, the Treasury Department released its income tax withholding tables, updated to reflect changes stemming from the Tax Cuts and Jobs Act. The new ....

Bloomberg News quoted Ed Reitmeyer, Mid-Atlantic Regional Partner-in-Charge of Tax & Business Services, in an article about tax strategies for owners of pass-through businesses under the new tax law.


As Seen In

Bloomberg News quoted Ed Reitmeyer, Mid-Atlantic Regional Partner-in-Charge of Tax & Business Services, in an article about tax strategies for owners of pass-through businesses under the new tax law.

If exploiting a tax loophole is as much an art as a science, then the tax planning profession is poised for a creative renaissance. The ....

Fox Business spoke with Tax Principal Michael D'Addio about the need to adjust paycheck withholdings under the new tax law.


As Seen In

Fox Business spoke with Tax Principal Michael D'Addio about the need to adjust paycheck withholdings under the new tax law.

As employees begin to receive their updated paychecks based on the new tax code changes, many are seeing incorrect withholding amounts, which could lead to ....

Long Island Business News reported on the Marcum tax panel the publication's editor is co-moderating with Melville Office Managing Partner Carolyn Mazzenga.


As Seen In

Long Island Business News reported on the Marcum tax panel the publication's editor is co-moderating with Melville Office Managing Partner Carolyn Mazzenga.

Long Island Business News Editor Joe Dowd and Marcum Melville Office Managing Partner Carolyn Mazzenga are set to moderate a series of panel discussions tonight ....

Bloomberg’s Talking Tax podcast invited Tax Principal Michael D’Addio onto the show for a discussion about whether the new tax law will drive pass-through entities to convert to C-Corporation status.


As Seen In

Bloomberg’s Talking Tax podcast invited Tax Principal Michael D’Addio onto the show for a discussion about whether the new tax law will drive pass-through entities to convert to C-Corporation status.

The new tax law lowers the corporate tax rate to 21 percent—a change that some lawmakers have suggested could prompt pass-through entities to convert to ....

Long Island Business News quoted State & Local Tax Leader Paul Graney in an article about options New York State is considering to counter the regional tax impact of the federal Tax Cuts & Jobs Act.


As Seen In

Long Island Business News quoted State & Local Tax Leader Paul Graney in an article about options New York State is considering to counter the regional tax impact of the federal Tax Cuts & Jobs Act.

Facing new federal rules that limit state and local tax deductions, New York and California are considering options to give their residents a big federal ....

CFO.com published an article by Tax Leader Joseph Perry and Tax Principal Michael D'Addio, discussing the pros and cons of C-corporation v. pass-through entity status under the new tax law.


As Seen In

CFO.com published an article by Tax Leader Joseph Perry and Tax Principal Michael D'Addio, discussing the pros and cons of C-corporation v. pass-through entity status under the new tax law.

A 21% income tax rate might sound appetizing to some pass-through entities, but C-corporation status doesn't suit every organization.

Associated Press quoted Tax Principal Michael D'Addio in an article about how small businesses are capitalizing on the new tax law.


As Seen In

Associated Press quoted Tax Principal Michael D'Addio in an article about how small businesses are capitalizing on the new tax law.

Although there are still many unknowns about the tax law that took effect Jan. 1, some small business owners have already figured out that they ....

U.S. Supreme Court Will Hear South Dakota's Sales Tax Case


Tax Flash - State & Local Taxation

U.S. Supreme Court Will Hear South Dakota's Sales Tax Case

On January 12, 2018, the United States Supreme Court decided that it will hear a South Dakota case (State of South Dakota v. Wayfair Inc., ....

International Taxation Brochure

DOWNLOAD
 
 

Contacts

Select the region to view contacts.

Mark  Chaves, International Tax Co-Leader, Tax & Business
Practice Leader
International Tax Co-Leader
Tax & Business
Miami, FL
FL

Douglas  Nakajima, International Tax Co-Leader, Tax & Business
Practice Leader
International Tax Co-Leader
Tax & Business
Philadelphia, PA
PA

Kristina M. Albarella, Director, Tax & Business
Director
Tax & Business
Melville, NY
NY

Elizabeth  Mullen, Partner, Tax & Business
Partner
Tax & Business
New York, NY
NY

Steven  Wintersteen, Partner, Tax & Business
Partner
Tax & Business
Chicago, IL
IL

 
 
2018 YEAR-END TAX GUIDE

The Marcum 2018 Year-End Tax Guide continues our tradition of providing timely tax guidance for the upcoming year.

 
 
HAVE A QUESTION? ASK MARCUM
 
 
STAY IN TOUCH.

SIGN UP TODAY FOR MARCUM'S NEWSLETTERS.

ABOUT MARCUM LLP

Marcum LLP is one of the largest independent public accounting and advisory services firms in the nation, with offices in major business markets throughout the U.S., as well as Grand Cayman, China and Ireland.

Learn More

CONNECT WITH US
OFFICES

Headquarters
750 3rd Avenue, 11th Floor
New York, NY 10017

Find an Office

(855) MARCUM1
info@marcumllp.com

FOUNDATION

Marcum Foundation

AFFILIATIONS

Leading Edge Alliance

Privacy Policy

This website uses cookies to learn how visitors interact with our website so that we can improve our services and your online experience. By using this website, you agree to our privacy policy.