Tax Services

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

Program 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.

Maximize 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.

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.