Turquoise Tax Advisory

International Tax

Turquoise Tax Advisory has a strong focus on international tax matters, having represented a wide range of multinational clients around the world. Whether your business affairs involve foreign sales or investments, or if you are conducting business in the US from a foreign jurisdiction, as your advisor, we will examine the necessary US provisions to ensure that you have the most efficient tax structure and your overall tax burden will be minimized. Our International Tax Practice covers the range of all international business activities and taxes. We provide ongoing advice to U.S.-based multinational businesses concerning all U.S. federal and state income tax rules relevant to foreign operations, as well as general advice concerning foreign taxation. 

Turquoise embodies a multidisciplinary approach to international tax matters in various practice areas across the nation such as:

·        intellectual property,

·        structuring inbound and outbound businesses,

·        cross-border mergers and acquisitions,

·        reorganizing and restructuring multinational corporate groups,

·        transfer pricing, supply-chains, contract manufacturing,

·        foreign entity classification,

·        foreign tax credits,

·        foreign currency transactions,

·        profit repatriations,

·        tax treaty issues,

·        international controversies before the IRS,

·        taxable presence and permanent establishment exposure for corporations and private equity funds, and

·        hedging transactions.


Streamlined Filing Compliance Procedure

The compliance of US taxpayers living in foreign countries has historically been an issue that was a legal requirement, but was very difficult for the US tax authorities to enforce. This created a situation in which US taxpayers living offshore often ignored their US tax filing obligations.    

The world we are living in has changed dramatically. Since 9/11, the US has greatly increased its ability to enforce existing laws against US taxpayers residing in foreign countries. Changes in data sharing technology and law enforcement powers have given the Internal Revenue Service broad powers to identify and penalize noncompliant US taxpayers. In addition, the Internal Revenue Services and Department of Treasury has negotiated intergovernmental agreements with over 140 countries in which foreign banks are required to audit their client accounts for US taxpayers and disclose them to the IRS.

Fortunately, the IRS has implemented a program in which offshore taxpayers who come forth and disclose with their unfiled taxes and bank account disclosures can be in compliance with minimal or no penalties. This program is called the Streamlined Filing Compliance Program and is limited to those who the IRS has not previously contacted, so it is important that noncompliant taxpayers enter into the program as soon as possible. 


Pre-Immigration Planning

The US tax system can be very different than tax systems in many other countries.  This is because the United States is a country which administered by an extensive and functioning legal system that is unique in its complexity and challenges.  

Unlike many countries in which taxes are imposed directly on earning at the source in which it is earned, the US relies on a system of extensive self-reporting by its citizens in which they are required to report income.  The US then applies sophisticated analysis tools to determine and target those individuals that are not in compliance with its many laws.  The tax authorities then can penalize noncompliance with very harsh penalties. The US tax law is very clear in its rulings that ignorance of the law is not an excuse for noncompliance.  Given that international taxation is one of the most complex areas in the entire US legal system, this can create a tremendous burden for new immigrants to the United States.  

This can be a very challenging burden for foreign nationals who have business holdings and wealth overseas because advising a client in this field typically involves a combination of multiple specializations in taxation. Unlike many countries, the Unites States government does not see itself as the primary advisor on their citizens regarding tax matters. Instead, it delegates this responsibility to professional CPAs and tax attorneys who serves as the US tax law interpreters and implementers of the US tax system. In fact, the US tax authorities require its taxpayers to seek and rely upon professional advisors, such as CPAs and attorneys to advise them on tax matters. Failure to seek professional advice on complex matters can lead to negligent penalties or worse for the US taxpayer.      

Fortunately, unlike many countries, this means that the US government permits and even encourages its citizens to make whatever arrangements are necessary to minimize their taxes. At Turquoise, we have the expertise to ensure that your tax burdens are minimized and complied with.  

In providing pre-immigration tax planning, Turquoise will:

  • Examine your business holdings and consider tax strategies to ensure that corporate tax issues are addressed and taxes are minimized.

  • Review Estate Planning strategies to minimize estate taxes.

  • Consider gifting strategies to transfer wealth to the next generation of children or other relatives.


Transfer Pricing

Transfer pricing is the allocation of a multinational companies profits to jurisdiction in which those profits were derived. This determination is made by examining the economics of the company and determines how and where value is being added by each of the business units.    

In the past, this was considered a big company issue for US multinational corporations.  However, this is changing. As international tax authorities are growing in their sophistication, they are increasingly focusing on transfer pricing as the key area in which they can generate tax revenues for their country. Additionally, US tax authorities are now focused on transfer pricing for mid-sized and even small businesses with significant cross border operations.  

Tuquoise provides deep strategic insights into your global supply chain structure and intellectual property planning to minimize your companies effective tax rate across multiple countries. Turquoise prepares Transfer Pricing documentation for tangible goods and intangibles, loans and services. With a Big-4 background in a leading transfer pricing think tank in Chicago, Turquoise is unique as a practicing transfer pricing firm in the state of Washington outside of the major public accounting firms.


Business Tax Planning and Entity Structuring

The United States Tax Code has the most complicated tax system in the world. When it comes to the tax law, apparently simple matters can become complex very quickly. This is because many different laws can come into play when considering a single transaction. Unfortunately, the vast number of tax rules that are written for large businesses, also apply to the entrepreneur with limited resources. The rules are so complex that it is often difficult for even the most astute business owner to realize they have a potential tax issue. The IRS standard response to errors is unforgiving because they assume the taxpayer is negligent if they have not contacted their tax advisor for even the slightest issues. As a tax professional trained in Big-4 public accounting, we are trained to draw up a vast amount of research and knowledge to identify and resolve very complex tax matters. Through effective tax planning, we try to ensure that you are able to arrange your affairs to take advantage of every benefit that you are legally and rightfully entitled to. Our services include:

  • Entity Structuring

  • Reorganizations and Liquidations

  • Acquisitions

  • Research and Development Tax Credit

  • Due Diligence


Income Tax Return Compliance

The United States Tax Code is the most complicated tax system in the world. When it comes to the tax law, apparently simple matters can become complex very quickly. This is because many different laws can come into play when considering a single transaction. Tax return preparation by a Certified Public Accountant can help ensure that you take advantage of the full range of deductions that you are entitled to. Additionally, having a professional review your return allows them to gain greater insight into your financial situation so that they can advise you on how to minimize your taxes now and in the future.

Whether you need a 1040 Individual Income Tax Return, 1120 Corporate Tax Return, 1065 Partnership or a 5471 for Foreign Corporations, we will prepare your returns quickly and accurately.


Cross Border Estate & High Net Worth Planning

Estate Planning refers to a very broad category of tax strategies that are applicable to transfers of wealth between generations. These strategies are mostly for high-net worth individuals; however, families at most every level of wealth should have a tax efficient plan in place to ensure that a person's final wishes are properly carried out.

  • Estate, Trust and Gift Planning

  • Succession Planning Strategies

  • Expatriate Compliance and Planning

  • Passive Foreign Investment Companies

  • Global Mobility, Cross Border Executive Compensation and Benefits