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GILTI updated and revisited
US entities that own greater than 50% of a business established in a foreign country are now subject to a tax on Global Intangible Low-Tax Income (GILTI) of their subsidiary controlled foreign corporations (CFC). US Corporations are eligible for certain deductions and foreign tax credits on the income and tax associated with GILTI. Similarly, pass-through entities, such as Subchapter S-Corporations, partnerships and Limited Liability companies (and the individuals that own them) are also subject to the new GILTI tax but do receive the same deductions and tax credits as Corporations.
Download The Full GILTI Article!
MKS&H International Tax & Accounting Services
International enterprises face many challenges when expanding their business operations in the United States. MKS&H serves as a trusted business partner who collaborates with foreign-owned businesses to help navigate US accounting standards (GAAP); international accounting standards (IFRS) and the complex US tax law.
Audit professionals within MKS&H’s international practice area have completed the IFRS Certificate Program and they understand the accounting impact of the latest standards and amendments issued by the IASB, have obtained proficiency in complex IFRS areas including financial instruments and business combinations and can apply the fundamental principles of IFRS across a broad range of accounting topics.
Services for Foreign-owned US Subsidiaries
MKS&H has extensive experience working with Foreign-owned US subsidiaries to meet their tax and accounting needs. Our services start with teaming up with executives to establish a business presence in the United States. We can help by facilitating the establishment of business entities, accounting systems, and US state registration.
MKS&H provides to US subsidiaries of global entities by providing services that include: tax provision in accordance with ASC 740, preparation/review of federal and state tax returns, and consulting on corporate structures to minimize effective tax rates. We also guide entities through navigating US State nexus to determine where your company has state income tax and sales tax exposure.
We work with a variety of companies with revenues up to several hundred million dollars in industries such as: manufacturing, distribution, technology, construction, transportation, food processing and professional services.
MKS&H serves as the out-sourced accounting department to Foreign-owned US subsidiaries:
The US tax reporting system is complex and requires expert knowledge and experience to prepare forms and help guide your business through our tax system. We can be called upon to support your tax department’s efforts by providing computations and schedules or we can be leveraged as an out-sourced tax department for your US operation.
- Consulting on US entity structuring to minimize effective tax rates
- Navigating US Ssate nexus for your multiple state operations
- Preparing federal and state US tax returns including foreign information reporting compliance
- Tax planning for multi-national businesses and key employees
- Calculating quarterly US tax payments
- Computation of 263A and inventory adjustments
- Tax compliance for greater than 25% foreign owned US businesses (IRS Form 5472)
- Foreign tax credit analysis and planning for unused FTC
- Preparation of US tax returns for key employees
- Navigating through US voluntary disclosure programs
Services for Foreign-Owned US Start-ups:
MKS&H excels at expediting the complex aspects of structuring a business, including entity selection and formation. We also guide you through selecting the most tax advantageous US state for organizing and operating your business.
Once organized, we help your new business establish payroll accounts with federal and state authorities while guiding you through the process of establishing a US bank account so that you can begin meeting your US payroll quickly. Further, we help you navigate the independent contractor rules and determine the best approach for your business.
Additionally, we assist you in establishing a US accounting system that ensures compliance with strictly enforced US foreign information reporting and US income tax filings. We take the time to get to know you and your business, acting as a trusted advisor and liaison for all of your business activities in the US.
Services for Expatriates and Dual Citizens
Need clear answers to your US tax questions?
We can help you identify areas where you are out of compliance with US foreign asset disclosure requirements, prepare tax filings, represent you before the IRS and help you understand your options under US Voluntary Compliance programs.
Have questions about the 2018 US tax law? Click here to read our blog.
Kathy Davis is our International Tax & Accounting Services team lead. She provides a wide range of tax and consulting services to the firm’s diverse client base, including construction contractors, manufacturers, cemetery CEOs, large privately owned companies, and high-net worth individuals.