International Engineering Firm

Approach & Results

Client Profile
McGuire Sponsel partnered with a U.S.-based company specializing in engineering services. This limited liability company (LLC) operates globally, with subsidiaries in multiple countries and substantial international activities. In the current tax year, the client underwent significant structural changes, including several acquisitions and the liquidation of a subsidiary.

Process
Our Global Business team thoroughly analyzed the client’s recent structural changes, focusing on the impact of new acquisitions and subsidiary liquidation. We then meticulously identified the U.S. filing requirements for each short period resulting from these structural changes. This detailed approach ensured that all tax obligations were accurately addressed, taking into account the varying timelines and regulations associated with each corporate action.

A key aspect of our process involved examining the client’s foreign tax liabilities. Through this analysis, our team identified an opportunity to optimize the client’s tax position by making a High Tax election. This strategic decision was aimed at decreasing the Global Intangible Low-Taxed Income (GILTI) inclusion for U.S. tax purposes, potentially leading to significant tax savings. The entire compliance process, from initial analysis to the completion of all necessary filings and elections, was executed within a one-month timeframe.

Project Results
Our Global Business team successfully delivered all required forms and statements on schedule, meeting critical deadlines and ensuring the client’s full compliance with U.S. tax regulations. Our comprehensive approach to analyzing short-period filing requirements and implementing the High Tax election strategy provided the client with a more favorable tax position, potentially reducing their overall tax liability.

Our team has committed to ongoing support for this client and will continue to analyze the company’s evolving structure and identify additional tax-saving opportunities in the future. This proactive approach ensures that the client will benefit from our expertise in international tax compliance and optimization on an ongoing basis.