International Tax

Foreign operations and expansion out of, or into, the United States can be complicated from a tax perspective. You need sound, pragmatic tax advice to avoid complications and efficiently comply with relevant tax jurisdiction laws, rules and regulations.

Marcum’s International Tax Services Group assists businesses and global families with tax planning strategies to minimize their worldwide tax obligations and meet business and financial objectives. With Marcum, you have access to a wide array of planning, consulting and compliance services.

In addition, Marcum is a founding member of LEA Global: Leading Edge Alliance, an international association of independently owned accounting and consulting firms with a presence in more than 100 countries, and is the exclusive U.S. associated partner firm of ECOVIS, a multinational professional services organization operating on six continents. Our international tax professionals are well-equipped to serve the specific needs of large international corporations, foreign nationals, high net worth individuals, family business owners and local business operators, among others.

The right approach to international tax issues can be critical to business success. For advice you can trust, ask Marcum.

Key International Tax Services

Creation, implementation, management of organizational structures.
Mergers and acquisitions (Outbound, Inbound).
Transfer pricing.
Structured finance.
Income tax planning and compliance for foreign investment in U.S. real property (FIRPTA) in U.S. real properties.
Ownership structuring.

Consulting services for organic overseas expansion.
FIN 48 implementation and review.
Transactional analysis.
PFIC reporting.
Certifying Acceptance Agent services.
Expatriate global services.
Planning and tax compliance related to the Tax Cut and Jobs Act of 2017.

International Tax Planning for Corporations

Experienced Marcum international tax professionals provide you with advice and guidance on aligning your company’s operations to maximize direct and indirect tax efficiencies. This can include realigning functions, risks, responsibilities and assets to allocate global profits in a manner that’s tax efficient, risk averse and compatible with your company’s operations. We also provide planning specific to foreign-owned businesses, and U.S. companies with foreign subsidiaries, with particular emphasis on the provisions of the Tax Cut and Jobs Act of 2017.

Transfer Pricing

Multinational enterprises (MNEs) face ramped up enforcement focused on their transfer pricing policies by the IRS, OECD and other relevant taxing authorities. In today’s business environment, MNEs must be prepared to properly document and defend the transfer of property, services and intangibles among affiliated entities.

Marcum’s International Tax Services Group has the knowledge and technical expertise to help you address your most complex transfer pricing issues, including:

Design and implementation of your transfer pricing policies.
Preparing IRS-required transfer pricing documentation and audit defense.
Preparing OECD and other foreign transfer pricing documentation.

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Global Compliance Services

With increasing frequency, U.S. companies deploy technical talent, sales managers and executives overseas to conduct business, and foreign companies bring their employees to the U.S. for short- and long-term assignments. Marcum provides a variety of income tax compliance and consulting services for these clients. In addition, Marcum assists companies in navigating the complexities of Social Security and employment-related taxes for employees assigned to foreign jurisdictions. Services are customized based on your needs, facts and circumstances.

Latin America and Caribbean

For businesses poised to conquer new frontiers, whether venturing into the Latin America and Caribbean (LatAm) region or branching out to the vibrant U.S. market, the journey is fraught with regulatory labyrinths, cultural complexities, and strategic challenges. With Marcum’s experienced guidance, this journey can be transformed from a daunting endeavor into a successful global expansion.

Marcum stands as a pivotal ally for companies looking to:

Enter and grow in the LatAm and Caribbean markets with a strategic edge by understanding the local business terrain and consumer culture.
Seamlessly transition into the U.S. market, leveraging our deep knowledge of American business practices and regulations.
Benefit from a dual-market perspective that maximizes opportunities and minimizes risks across borders.

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EB-5 Investor Services

EB-5 regulations require immigrant investors to prove invested capital was “obtained through lawful means.” This two-step process includes: 1) preparing a detailed report showing how the investor obtained the funds used for the investment; and, (2) providing a clearly documented “path of funds” from the original source to the investment enterprise’s bank account.

Marcum’s international tax professionals have assisted investors around the world in complying with the provisions of EB-5 and preparing the Source of Funds Report and interview questionnaire required by the U.S. government. After determining the completeness and accuracy of your data, our professionals collaborate with your immigration attorney to ensure the process proceeds as seamlessly as possible.

Relationships are the foundation of Marcum’s business, and, once established in the United States, many investors who originally engaged us for assistance with the EB-5 application process continue to rely on us for tax advice and guidance for their other business challenges.

Passive Foreign Investment Company

If your company meets the conditions necessary to be considered a passive foreign investment company (PFIC), Marcum can help you navigate the complex and sometimes punitive U.S. income tax filing requirements. In addition, Marcum provides proactive tax planning in this area so you avoid unwanted surprises. A PFIC and its shareholders are subject to recordkeeping requirements regarding cost basis of shares in the PFIC and other items that can be challenging and confusing. Our professionals are here to help.