International Tax Preparation

Our International Tax Services Team assists companies that are expanding their operations internationally. Whether that means a move or expansion into or out of the United States, for operations or personnel, expert advice is crucial. Our International Tax Services Team has the extensive expertise and the technical knowledge to assist in structuring transactions worldwide. Tax Planning Consulting Services
Our team provides professional tax planning and consulting services in connection with the following:

Businesses and Entities

  • Optimization of structures for foreign investment and business operations in the U.S.

  • Optimization of structures for U.S. investment and business operations outside of the U.S.

  • Structuring for cross-border acquisitions, sales and other exchanges

  • Structuring for acquisition, operation and disposition of U.S. real estate

  • Controlled foreign corporation issues

  • Interest Charge Domestic International Sales Corporations (IC-DISCs)

  • Passive Foreign Investment Company issues (PFICs)

Individuals and Trusts

  • U.S. executives working and residing overseas

  • Foreign executives working and residing in the U.S.

  • Tax issues for non-citizens immigrating to the U.S.

  • Tax issues for individuals considering expatriation from the U.S.

  • Gift, trust and estate considerations for non-citizens with U.S. based assets

  • U.S. beneficiaries of foreign trusts

Other Matters

  • Income tax treaties and totalization agreements

  • Foreign tax credits

  • Subpart F and other anti-avoidance rules

  • Tax aspects of foreign currency exchange

  • Matters related to payments of U.S. source income to foreign persons

Withholding Tax Services

Our team provides advice to companies and individuals regarding issues related to withholding and reporting compliance, including:

  • U.S. withholding and reporting for payments made to foreign persons

  • Use of Qualified intermediaries

  • Foreign withholding tax matters

  • Application of income tax treaties to amounts subject to withholding at source

  • Application of U.S. withholding rules to offshore withholding agents

  • Backup withholding matters

Expatriate and Impatriate Tax Services
Our team provides tax planning and compliance services to U.S. executives on assignment overseas and their U.S. employers, as well as to foreign executives on assignment in the U.S. , including:

  • Consultation to foreign nationals and U.S. citizens living abroad with the objective of providing solutions to minimize taxes worldwide, including through the application of income tax treaties and social security totalization agreements

  • Preparation of U.S. income tax returns and other required filings for individuals with cross-border tax issues

  • Consultation to companies with executives on overseas assignment (inbound/outbound), including assistance to human resource and payroll personnel

  • Assistance with the calculation of gross-ups of foreign assignment allowances, tax equalization computations, and appropriate actual and theoretical withholdings

U.S. Tax Compliance

Our team provides a wide variety of tax compliance and preparation services related to foreign and international tax reporting, including:

  • General compliance services for U.S. corporations and individuals with foreign based businesses and investments

  • Preparation of and assistance with data gathering for U.S. international tax forms (1118, 5471, 8865, 8858, 5472, 1120-F)

  • Quantitative services related to U.S. international tax calculations (foreign tax credit, Subpart F, section 956, earnings and profits)

  • Accounting and tax preparation services for foreign nationals and foreign owned businesses

  • Withholding tax returns for U.S. payers to foreign persons

  • Assistance with U.S. individual tax identification numbers

  • Income tax services for U.S. individuals with beneficial interests in foreign trusts

  • Estate tax returns for nonresident aliens

IRS Matters

Our team provides support and representation services to taxpayers, partnering with the taxpayer and legal counsel, as appropriate, in connection with the following:

  • IRS voluntary disclosures for U.S. persons with undisclosed foreign income and financial accounts

  • Tax controversy, Competent Authority and other IRS matters

International Individual Mobility Services

Service team understands the value of worldwide human capital resources and assists individuals as well as companies better manage transfers worldwide. As a service of the Firm’s International Tax Services Practice group, the team has the extensive expertise and technical knowledge to assist U.S. expatriate individuals living and working abroad, and foreign nationals living and working in the U.S., with pre-departure, post-arrival, and tax planning and compliance services at the individual level, as well as with planning, implementation, and coordination of the transfer of global employees at the company level. The Firm works closely with our global Leading Edge Alliance™ affiliates to assist clients with minimizing their worldwide tax burden, while coordinating tax planning and compliance services with the affiliates.

Some of the many services provided by Marcum include individual income tax filings, FATCA compliance, tax cost projections, tax gross up and equalization calculations, pre-departure and post-arrival consultations, and tax planning and advisory services for companies, employees and individuals.

Tax Cost Projections - Marcum can provide tax cost projections related to the employee’s or individual’s move.

Pre-Departure Consultation - The employee or individual will receive pre-departure consultation from the home country’s affiliate in the home country or from Marcum before departing the U.S.

Post-Arrival Consultation - The employee or foreign national will receive post-arrival consultation from Marcum upon arriving in the U.S. or in the host country, from our affiliate.

Individual Income Tax Compliance Services - The employee’s or individual’s U.S. tax compliance and FATCA reporting will be serviced by Marcum. We can also coordinate foreign reporting with the international affiliates or the individual’s own accountant in the foreign country.

Tax Gross-up and Equalization Calculations - Marcum can prepare or review the tax gross-up and equalization calculations of employees.

Tax Planning and Advisory Consulting - We pride ourselves in providing high level, personalized, client-focused tax planning and advisory services. Our clients directly communicate and work with very knowledgeable and experienced professionals at Marcum.