US inbound tax services

Evaluate and benefit from the tax opportunities and challenges of investing in the United States.

PwC’s US inbound tax team is a national network of cross-disciplinary professionals dedicated to understanding the unique nuances non-US based MNCs face. We provide technical support and assist companies in formulating their US inbound policies.

We work with businesses to address:

Business and tax alignment  Align cross-border business and tax objectives.

Acquisitions and dispositions  Evaluate the US tax implications of US inbound acquisitions and dispositions designed to implement key initiatives.

Compliance  Address compliance requirements with respect to US federal and state tax laws, and hot topic areas such as transfer pricing and FATCA for US inbound companies.

US income tax treaties and competent authority  Determine the applicability and desirability of obtaining the benefits of US tax treaties in the context of cross-border financing and investment, international mergers, acquisitions and dispositions.

US tax benefits  Consider federal and state tax benefits, including credits and incentives available to US inbound companies—especially research and development credit.

Legislative and regulatory services  Monitor real-time developments on fast-moving US federal and state legislative and regulatory developments and consider the implications to US inbound companies.

Audit support  Respond to IRS and state revenue services’ challenges, such as increased focus on debt versus equity for US inbound financing.

In defense of water’s edge reporting

State tax authorities are increasingly focusing on and reviewing multinational taxpayers. Several have enacted legislation to provide exceptions to their water’s-edge reporting rules to include in a water’s-edge return the income of non-US entities doing business in or incorporated in so-called tax havens. States risk casting a wide net over all taxpayers with 'foreign' activity. State lawmakers are not considering the potential unintended consequences of those efforts, which could result in an overall reduction of state revenue.

Todd Roberts examines the unintended potential consequences of those changes in our TaxNotes series.

 

 

Contact us

Christopher Kong
US Inbound Tax Leader
Tel: +1 (416) 869 8739
Email

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