International Tax Services
Why Choose RINA?
We believe it is important to approach the tax aspects of your business not only from the point of view of meeting statutory requirements but also with a continuous effort to advise you on the most advantageous techniques available to address your unique cross border and international tax needs.
- We believe in developing strong client relationships and are available to answer your questions anytime.
- We take complex information and break it down so you understand the issues.
- We help you navigate the rules so you can make decisions that are right for you and your business.
- We can handle any size transaction from multi-state or stand alone transactions for both closely-held or public companies.
We provide international taxation services, applying expertise gained through Big Four accounting firm and regional accounting firm experience. In addition, through our affiliation with MGI Worldwide, an international accounting network of independent professional service firms, RINA has access to the local knowledge of tax professionals in over 250 offices throughout 76 countries.
How RINA Can Help
We specialize in the following international tax areas:
- Transfer Pricing issues involving related taxpayers
- Export incentives such as exporting through an IC-DISC
- Compliance with FATCA Regulations (Foreign Account Tax Compliance Act)
- Outbound international tax transactions (U.S. persons doing business in foreign countries)
- U.S. income tax planning and compliance pertaining to foreign taxpayers operating in the U.S.
- Selection of the most tax-efficient entity for foreign operations
- Income tax treaty analysis
- Tax-efficient use of debt versus equity in capitalizing operations
- Constructive dividend/Subpart F income analysis
How We’ve Made a Difference
Transfer Pricing: We prepared a Transfer Pricing Study for a U.S. company which distributes networking equipment (modems and routers). In this study, we determined the arms-length price for the purchase of parts from the Taiwanese parent company. One of our findings was that the profit margins of the U.S. subsidiary were much greater than that of the comparable companies that were reviewed as part of the engagement. Therefore, we worked with the General Manager in the U.S. to restructure the contracts for the purchase of goods from Taiwan, effectively reducing the U.S. profits by $700,000.
“Since the U.S. tax rate was higher than the tax rate in Taiwan, we were able to help them significantly reduce their worldwide tax” – Tom Neff, International Tax Chair.
Contract Structuring: A U.S. distributor of mining equipment had entered into a contract to sell $7M of product to a Canadian company. RINA assisted them with the structuring of the sales contracts between Canada and Switzerland (the manufacturer’s location), and set up of a service agreement between the U.S. company and Switzerland. As a result, the sales were sourced to Switzerland which avoided our client’s exposure to U.S. taxation.
“By careful analysis of the U.S./Switzerland Income Tax Treaty, we were able to advise our client how to structure their multi-national sales and service agreements in a way that took full advantage of the treaty benefits”– Brenda Jemmott, co-chair of the International Tax Group.
Our Global Accounting Network, Your Local Contact in the World
RINA is a member of MGI Worldwide, a Top 20 international accounting network of independent audit, tax and accounting firms, which brings together the expertise of some 6,000 professionals in over 250 locations around the world. Our membership enables us to keep abreast of important new developments, while providing a seamless international service to any of our clients looking for support abroad. Through MGI Worldwide, our firm benefits from connections with people we get to know and trust in all corners of the globe. We can help you and your operations with a quick phone call to one of our colleagues or a complete service offering — whatever you need to make your international business a success.
MGI Worldwide is a quality controlled network and, like all member firms, we are subject to review of our quality assurance systems and procedures against international standards.
For more information on MGI Worldwide visit www.mgiworld.com.