U.S. Inbound Investment
McGuire Sponsel’s team of international tax experts provide guidance to clients and help them understand the various complexities of U.S. tax laws and how they affect foreign-owned U.S. businesses. Understanding that the U.S. tax regime can negatively impact non-U.S. companies, our professionals offer cross-border tax planning strategies to the U.S. subsidiary and its foreign parent corporation in order to minimize their global effective tax rate while fulfilling their business needs.
Our U.S. inbound tax planning strategies focus on a number of factors that potentially impact U.S. investments, including:
- Tax regulations of the foreign jurisdiction where the foreign corporation is located
- Foreign corporation’s other foreign investments and overall global tax position
- Foreign corporation’s legal entity structure
- Need for a holding company
- Current and expected profitability of the foreign corporation and their U.S. investments
- Cash flow requirements of the foreign corporation and their U.S. investments (Repatriation Strategy)
- Current and planned debt financing for the foreign corporation and their U.S. investment(s)
- Activities, functions and ownership risks of the U.S. investment (Transfer Pricing)