In order to navigate today’s dynamic global economic landscape and the impact of the recent U.S. tax legislation changes enacted by the 2017 Tax Cuts and Jobs Act, LHF partners with our multinational clients to co-develop a customized global business model which efficiently and effectively manages inbound and outbound international transactions.

LHF’s presence extends well beyond the United States borders. LHF is the only firm in New York, and one of only three firms in the country, to have been selected for membership in EuraAudit International, a premier association of international accounting firms.

Our International Services Focus on 4 Key Areas: 

 1. Value Chain Alignment 
LHF provides tailored solutions for our multi-national clients through review of your company’s supply chain management.  LHF introduces strategic alignment concepts to your operational footprint which aligns your business goals and tax minimization efforts.  Since the 2017 Tax Cuts and Jobs Act was enacted, we have contributed to so many success stories in which our clients realized significant tax savings and reduced operational costs.

2. International Mergers, Acquisitions, Consolidations and Reorganizations 
Tax arbitrage is the practice of profiting from differences that arise from the ways that transactions are treated for income tax purposes.   The complexity of the Internal Revenue Code affords many incentives to U.S. companies to restructure their businesses in the most advantageous way in order to pay the least amount of tax.

LHF provides consulting services to our clients with international deals, transactions and corporate reorganizations. We understand that these transactions can be overwhelming, complex and stressful. During these transactions, we remain side-by-side with our clients – from negotiation through execution and beyond – to ensure the best possible outcomes.

Techniques include:

• Due Diligence
• Structuring & Modeling
• Integration

Domestic and International Compliance and Regulatory Reporting
Since the 2017 Tax Cuts and Jobs Act was enacted, our consulting services have made notable contributions to the success of these transactions while also improving uncertainty and reducing risk.

3. International Tax Compliance 
In addition to the vast complexities of international tax compliance, the recent uptick in foreign tax regulations and aggressive civil enforcement initiated by local country tax authorities creates significant challenges for mufti-national businesses.

While LHF maintains a strong understanding the nuances of international tax compliance regulations and requirements imposed by foreign countries, for multifaceted and difficult international matters, LHF’s co-sourcing relationships with the tax professional members of our international association ensure timely and accurate reporting – while reducing overall exposure.

4.  Transfer Pricing Studies and Services 
Many low-taxed jurisdictions offer “business development services” which fosters tax incentives to U.S. businesses by transferring income offshore. A significant focus of the Internal Revenue Service related to international taxation is their efforts to ensure that U.S. taxpayers clearly reflect income attributable to controlled transactions and to prevent the evasion of income.  Found in the statutory laws under the IRC §482 regulations, the Internal Revenue Service is permitted to make adjustments to a U.S. taxpayer’s items of income and expenses for which they deem necessary in order to prevent the evasion of income taxes, or to clearly reflect the income of entities with common ownership or control.

A Transfer Pricing Study, a must have report in today’s global environment, is an economic study of your business.  It provides a full-length study of your business on your products or services, comparable market pricing, market fluctuations, labor costs, and fair market value analysis of business transactions.

LHF with its association partners analyzes your global business model and the business transactions between your existing company in a “high-tax” country and your foreign entities in “low-taxed” jurisdictions.

A Transfer Pricing Study will significantly reduce the potential exposure of adverse adjustments to your income taxes by:

• Proactively documenting the support for positions or treatment of various business transactions by an unbiased third-party professional.
• Show intent of compliance with contemporaneous documentation.
• Demonstrate reasonable cause and good faith for transfer pricing decisions through accurate and complete analysis.

Foreign-derived intangible income Deduction (“FDII”): The new tax benefit for corporate exporters

The 2017 Tax Cuts a Jobs Act (“2017 TCJA”) was one of the most sweeping tax reforms in the past 30 years. The new tax law provided tremendous corporate tax planning opportunities. One exciting new corporate tax planning opportunity was prescribed under IRC §250(a), the Foreign-derived intangible income deduction (“FDII”).

This new tax deduction was included in the 2017 TCJA with the intention of encouraging United Statesexports. The essence of this new regulation is that U.S. “C” Corporations that sell goods and services to foreign customers may be eligible to reduce the effective tax rate on certain qualifying income to 13.125%.

For a complete article on FDII and its implications, click here.