Services

Moore DM leads the market of accounting firms servicing international businesses that desire global coverage, depth of resources and seek a highly interactive relationship.

International Tax Services for Businesses:

U.S. Corporate Tax Services:

The Foreign Account Tax Compliance Act (FATCA) was passed in 2010 to help prevent tax evasion by U.S. citizens and taxpayers with offshore financial accounts. This was both an attempt to seek out individuals with accounts set up in prior years and to identify assets currently earning income outside the U.S. This came together with other IRS initiatives targeting offshore banks and U.S. taxpayers who were trying to hide assets.

Although many countries complained about the administrative requirements and invasion of privacy, they liked the idea of obtaining information about tax cheats and decided that maybe it wasn’t such a bad idea. Hence, the Organization for Economic Co-operation and Development (OECD) instituted the Common Reporting Standard (CRS). These rules became effective for 2016 information for certain early adopters (e.g., the UK). All organizations subject to FATCA will also have to comply with CRS.

Moore DM can assist you in your analysis of FATCA and CRS on your particular situation, aide in registering and establishing policies and procedures and assist with your ongoing compliance requirements.

It’s easy to succumb to the pressure to expand your global workforce. Today, companies with a growing international workforce are challenged with meeting the excessive demands put on internal resources, the associated costs, the complexities associated with navigating multi-national employee protocols, in addition to keeping international assignees happy.

Taking an integrated service approach, our Global Mobility Services team of professionals provides key support beyond the standard tax offerings, including assisting companies entering new markets with establishing processes from the ground up to comply with local payroll reporting and withholding requirements, individual tax compliance and real-time incorporation of host country compensation into home country reporting procedures.

Global Mobility Services:

Whether you are an international business invested in Latin America or a Latin American based business invested abroad, our Latin America Services Team offers a range of services custom tailored to help you start, develop or grow your venture.

Our Latin America Services Team is a group of bilingual professionals with deep knowledge of the Brazil – Latin America and U.S. business, accounting and tax environment and several years of experience providing practical and high value solutions to our clients.

We are dedicated to clients with investments into and from Brazil and Latin America and liaise extensively with the Moore Global firms in the region. This approach assists clients in navigating the enormous complexity of doing business internationally.

Doing business in and from Latin America can be extremely difficult. It can also be extremely rewarding. By getting involved early and staying involved, our team assists businesses and their employees and owners in achieving success. This is because planning, local knowledge and continuous monitoring are crucial. Clients spend more time developing and growing their business and less time dealing with distractions.

Services include:

• Advice regarding structuring of investment and ownership
• Coordination with lawyers, lenders and other professional service providers
• Assistance with entity formation and registration
• Due diligence support
• Compensation and tax planning and pre-assignment orientation for expatriates
• Ongoing support to the organization and its employees
• Reporting translation, both standards and language
• Repatriation strategies for profits

Our full-service offerings include:

• Audit and assurance
• Business consulting
• Business restructuring
• Corporate finance
• Family office
• Forensic and litigation support
• Governance, risk and internal audit
• Outsourcing
• Tax
• Trusts and estates

Industries served include:

• Real estate and construction
• Energy
• Non-profit
• Health care
• Manufacturing
• Professional services
• Technology
• Wholesale and distribution

As the U.S. is one of two countries in the world that imposes a federal income tax on its citizens regardless of where they live, being a U.S. citizen with an international presence requires specialized tax advice tailored to the financial circumstances and requirements of each individual.

Our dedicated international team of U.S. specialists endeavors to mitigate risk and optimize your tax affairs with careful planning and a personable approach.

Our services for private clients include, but are not limited to, the following:

• Tax compliance
• Historical reporting
• Pre immigration U.S. inbound/outbound planning
• Expatriation planning and reporting
• State and local tax planning and reporting
• Foreign disclosure reporting for foreign business owners and grantors or beneficiaries of foreign trusts
• Passive foreign investment company (PFIC) reporting
• Cross-border retirement planning
• Cross border tax minimization planning
• Voluntary disclosure strategy and compliance

In an increasingly global business environment, cross-border tax compliance is critical. If your company has affiliated entities engaged in any sort of cross border transaction (e.g., sale of goods, license or sale of intangibles, loans, guarantees or management fees), you need to assess these transfer pricing transactions up front.

Transfer pricing strategies must strike a delicate balance between achieving tax efficiencies and ensuring compliance with various jurisdictions. Complying and avoiding stiff penalties (fines as high as 40% of the underpaid tax in the U.S.) takes:

• Setting prices that are comparable to those paid in “arm’s length” transactions.
• Fully documenting the methods you use to set those prices.

Our tax accountants, attorneys and economists are well versed in the transfer pricing issues common among multinational corporations, public companies and domestic organizations doing business in multiple jurisdictions.

Let Moore DM help you formulate the best strategy for compliance and tax optimization based on your particular situation.

Transfer Pricing Services

• Full transfer pricing studies to identify appropriate strategies for tax optimization
• Policies and procedures review, development and implementation
• Transfer pricing documentation
• Assistance determining “arm’s length” transactions
• Cross-state and cross-border transaction review
• Base Erosion and Profit Shifting Master Documentation and Country by Country reporting
• Tax examination support

Trusts and estates are complex areas that can affect most high-net-worth individuals. Complex laws and tax rules surrounding trusts, estates and inheritances require careful planning and, sometimes, difficult decisions.

Whether it’s difficult tax rules for trusts or the financial implications of estate planning, getting it wrong can be costly.

Moore DM’s professionals have extensive experience in assisting families in building and preserving wealth through the creation and maintenance of customized estate plans and trusts. Our empathy and collaborative approach with other key advisors, such as lawyers and investment specialists, contributes to a comprehensive and flexible plan, which allows for ease of wealth transfer, flexibility to accommodate changing laws and the maximum amount left to your beneficiaries.

Also, we recognize that estate plans and trusts can be difficult to interpret and administer effectively. This is why we go beyond compliance services and give hands on, personalized advice to the settlors and beneficiaries.

Our unique and value-added approach has earned us most trusted advisor status with many of our family clients.

Our experienced specialists can assist with the following:

• Review of all estate planning and trust documents
• Estate and trust accountings
• Estate, gift and trust tax strategies
• Tax efficient vehicles such as family limited partnerships, grantor retained annuity trusts, defective trusts and charitable trusts
• Cash needs planning
• Selection of assets to gift
• Family meetings facilitation
• Estate, gift and trust tax returns
• Succession planning
• Trustee services
• Foreign trust accountings
• Foreign trust disclosures
• Other financial reporting
• Investment management oversight
• Feasibility and formation of family offices

If your company is setting up a new foreign corporation or has a foreign branch that it is incorporating, the following rules will likely impact your tax situation.

The U.S. Department of the Treasury and the IRS issued final regulations related to the tax rules covering the establishment of foreign operations. If your company is setting up a new foreign corporation or has a foreign branch that it is incorporating, these new rules will likely affect your tax situation.

Section 367 regulations now require different tax treatment for certain transfers by U.S. taxpayers to foreign entities. Essentially, the new regulations narrow the type of property subject to the “active trade or business” exception under Section 367, and eliminate the exception for transfers of foreign goodwill or going concern value, which often included a company name given to a new foreign entity.

The IRS and Treasury has also issued regulations related to Section 482 that apply to two or more interrelated and controlled transactions involving two or more provisions of the Internal Revenue Code. These regulations change how bundles of intangible assets that are transferred to a related foreign corporation are valued.

In plainer English, these changes will create taxable income for U.S. taxpayers in situations that were formerly tax exempt. They will require more extensive valuation of foreign transfers and more exacting documentation of the nature of the transfers.

Our tax team is fully aware of these regulations and their potential ramifications. We are available to discuss them with you and to help you document your foreign operations today so that you will be prepared for future audits or defense of your tax position on outbound transfers.