With the tremendous expansion of world trade and investment in the past
decade, multinational companies have elevated international tax planning to the
top of their lists of issues they must effective address to return profits to
their owners. Due to the highly fragmented nationalistic tax systems, there are
few general rules that are applicable across the board. Instead, clients are
forced to address the issues on a case-by-case, country-by-country basis. Over
the years, James Nobles LLC has gained considerable expertise in international
taxation. A few of the international tax services we provide to our clients are
Worldwide Tax Planning For those multinationals who
evaluate their worldwide tax burden with a view to reaching a targeted tax
rate, we identify strategies to reduce the worldwide tax burden, and then
assist the client in implementing the strategy.
Foreign Tax Credit Planning James Nobles LLC advises
clients on planning for optimum use of the foreign tax credit under the
complex U.S. rules which allow U.S. tax payers paying taxes to foreign
countries to receive, under certain circumstances, a U.S. tax credit for the
foreign taxes paid.
Debt-Equity Planning and Compliance Inbound foreign
investors and outbound U.S. investors obtain a tax beneficial structure by
optimizing the debt/equity ratios (or financial gearing) of their
investments. James Nobles LLC advises clients on compliance with debt/equity
tax considerations so as to permit clients to obtain their investor's
projected returns through the leveraging of the investment funds, while, at
the same time, maintaining compliance with the lenders' requirements.
IRS International Tax Controversies The U.S. Internal
Revenue Service has, in recent years, become more aggressive in auditing
companies, both outbound U.S. investors as well as inbound foreign investors,
for compliance with intercompany pricing and other rules. James Nobles LLC
provides representation to our clients in planning for these controversies as
well as representing the clients before the IRS.
Withholding Planning and Compliance Companies and individuals making cross-border payments (for example, dividends, interest, royalty payments) are often required to withhold taxes and pay the withheld amounts over to the tax authorities. If the appropriate amounts are not withheld, the payor will become liable for the tax. James Nobles LLC advises clients on compliance with the withholding laws and the methods of compliance.