Tax Services

Global Tax Desks

Ernst & Young International Tax Services introduced the Global Tax Desk Program more than 25 years ago to give multinational organizations real-time advice on tax issues, wherever their businesses operate. The program places seasoned international tax professionals from around the globe in major business centers where their skills benefit both local and home country clients. The result of this dynamic collaboration is truly integrated, global tax-planning advice in real time, regardless of different time zones and geographic borders.

This long-standing professional exchange program has revolutionized the way in which multinationals receive international tax advice. It gives you immediate access to Ernst & Young’s global network and all of its innovation, knowledge and implementation capabilities across borders and time zones. Our global desk network includes more than 250 tax professionals across 26 jurisdictions in 33 markets worldwide. All are ready and able to help in “real time” at both the headquarters and US locations.

Our Global desks in the US are based in New York, Chicago and on the West Coast, and can provide you with a team of seasoned professionals from across Europe the Americas, and the Asia Pacific Region. Our aim is to provide teams of senior foreign tax specialists who work side-by-side in the same location. As a result, international tax issues can be examined from every relevant perspective "on the spot." Ernst & Young's tax desks provide global advice, delivered locally.

Transfer pricing

We bring you a global perspective based on our long-standing experience of what really works in transfer pricing and tax effective supply chain management (TESCM).

Capital markets and treasury management

Treasury and tax departments of multinationals, domestic businesses, and even private investors of all types face increasing challenges to manage effectively business and market risks and efficiently deploy cash.

They also face growing scrutiny of their activities by tax authorities in the United States and abroad. In addition, the current volatility in the global markets creates further challenges and stresses for businesses in ways that reduce cash and increase effective tax rates.

Our Capital Markets practice consists of a network of tax professionals in key markets in the United States and overseas that focus on treasury and investment issues from financing to foreign currency. Our unique practice brings tax efficiency to treasury goals, whether companies are financing their domestic or cross-border activities, hedging their risks with derivatives, structuring investment vehicles, managing or repatriating cash, or just trying to figure out the best way to include foreign branch results.

Foreign Currency, Hedging and Investment Management

The group's Foreign Currency, Hedging and Investment Management Program offers a flexible set of services and tools designed to assess and manage tax risks and capture tax opportunities associated with the full array of treasury activities. In addition, in response to the increasing scope and frequency of IRS audits of financial products and transactions, we assist taxpayers with documenting and defending their positions against specialized teams at the IRS.

Inbound to the US

Maximise the possibilities of your US investment

Establishing, acquiring, expanding or selling a business in the United States demands that you stay on top of a rapidly changing tax and investment terrain. This is especially true in the current roller coaster global economy.

The rules and regulations governing US tax are complex and require knowledge and insight at the federal, state and local levels as well as in your home country. The success of your enterprise often depends on how well you understand the choices, the restrictions that apply and the pitfalls to avoid.

As unsettling as today’s unprecedented environment may be, it does provide the opportunity to supplement your strategic US acquisitions or rationalize and modify your existing US investments. It’s time to take a closer look at maximizing all the possibilities of your US investments.

We can help. We work closely with inbound investors and multinational organizations on a wide range of international transactions and related tax matters.

We understand that every business has a unique set of facts and resulting tax obligations. We take an integrated approach that addresses your needs at both the headquarters and local operations levels.

International tax planning services for inbound investors

Our multidisciplinary, multijurisdictional teams have the depth of knowledge, resources and experience to get to the heart of the issues that matter most to your business. No matter how complex your circumstances may be, we can advise you on the way forward toward reaching your full potential in the US and everywhere else you do business.

International tax compliance

For US multinationals, accuracy of international tax compliance is a critical piece of their tax environment puzzle. Yet getting this piece right is becoming increasingly complex and burdensome, severely taxing the resources of their tax departments. In surveys and one-on-one sessions with Ernst & Young, tax executives noted missed opportunities because their internal resources were dedicated to tax and accounting compliance and tax administration inquiries, challenges and assessments.

They also noted the concerning risks of not getting the international compliance piece of their tax function under accurate control, as the IRS increases pressure on the timeliness and accuracy of these specific filings. These realities have many multinational businesses asking these questions:

• Do we have the necessary tax infrastructure for data and access to information across borders?
• Do we have adequate personnel with the required knowledge of the many new US tax requirements for multinationals?
• In today’s risk environment, are we covering all of the pertinent foreign and US reporting requirements?

Ernst & Young‘s International Tax Compliance Services can help you complete this important piece of your tax puzzle.

Meeting the global tax challenge

Our International Tax Compliance services are designed to help you navigate today’s complex international compliance environment, while providing you with the flexibility and scalability you need. Our services also offer an approach that is not “one size fits all,” but one which blends with your unique requirements and service needs.

Our services include assistance with:

• Process Assessment
• Data Collection (Needs Identification, Approach, Collection, Analysis
• Forms Preparation and Technical Review (including Forms 5471, 8865, 8858, 1118,1042/1042S, 5472, 1120-F, and 8621)
• Section 987 computations for foreign branches and partnerships
• Preparation of FAS109 tax provisions in relation to the foreign affiliates
• Analysis and calculation of Subpart F income and foreign tax credit
• Earnings and Profits studies
• Identification, analysis and research of new issues related to the international compliance area

Our approach

The key to our success can be summed up in three words: team, tools, approach.

Team

Working together to meet your goals, our team brings to you:

• the right people: experienced international tax professionals committed to growth and continuous improvement. They will assist in the review and compliance of your international tax numbers.
• in the right place: an international presence with Industry-specific and local resources.
• at the right time: just-in-time professionals to address specific needs or to respond to specific questions from an organized global tax compliance network and a US-based Global desk network.

Tools

Our tax technology suite offers web-based tools for collaboration, data collection and knowledge sharing. Additionally, our Excel-based data management and analysis tool not only supports the tax return but also electronically transfers data into our tax return software for accurate and efficient return preparation. This suite of tools delivers powerful global connectivity.

Approach

Our proven automated, repeatable and scalable methodology allows us to provide high-quality services with competitive costs. Underpinned by leading practices and continuous improvement, the flexibility of our approach better addresses your specific needs.

Tax Effective Supply Chain Management

Amidst today’s challenges of regulatory action and economic turbulence, change is the only constant. For prescient enterprises, change also provides opportunities: to transform operations, redesign processes and emerge as stronger market leaders.

Business transformations that align operational and business changes with tax planning can yield significant after-tax savings and increase shareholder value. This is where Tax Effective Supply Chain Management (TESCM) becomes an essential tool of leading enterprises.

Our decades of experience helping businesses align their tax and operational goals have shown us that TESCM structures must be sustainable upon audit, flexible to provide scalability and designed to help reduce business disruptions during the TESCM project phases.

We will help tailor a TESCM structure that complements the scope of your business change and grows as your business expands.

What is TESCM?

TESCM is based on fundamental business changes that occur within the context of a company’s supply chain processes. These processes may include:.

• Product design
• Production planning
• Sales
• Research and development
• Manufacturing
• Overall corporate control
• Procurement
• Logistics
• Make vs. buy decision
• Marketing

Once a company’s business processes are identified as changing, the first step in a TESCM process is to sort the activities within each process as high-value versus routine functions.

High-value functions drive companies’ strategic decisions; they determine what products to produce, which markets to enter and how best to execute the corporate strategy. High-value functions entail risk, and should concomitantly earn higher returns.

It is people, however, who execute functions and manage risks. By redeploying decision-makers — and the functions and risks that they manage – to centralized and possibly tax-favored jurisdictions, companies may realize material operational and tax benefits through efficiencies and by earning a greater proportion of their profits in a tax-efficient location.

Routine activities, deriving a smaller amount of taxable profits, might remain in higher-tax jurisdictions or re-locate elsewhere as business needs dictate.

TESCM is the process of identifying and reallocating functions, risks and people in the most tax-efficient manner, within the context of a businesses’ overall operational goals and restructuring plans.