International Taxation

International Tax Advisors

Our International Tax Advisors have been delivering tax advice to both individuals and entities doing business and investing in the United States and abroad for over 20 years. International taxation is one of the most complex areas of taxation and is often divided into two areas: “Inbound” and “Outbound.” Inbound taxation refers to foreign investors with U.S. income and/or activities. Outbound taxation refers to U.S investors with foreign income and/or activities.

Investors that engage in cross-border transactions must keep abreast of accounting and tax developments in multiple jurisdictions. It takes tax planning on an international scale to effectively minimize the global effective tax rate, while keeping in mind any long-term business goals. The following are typical international tax services provided by our firm:

  • U.S. Inbound Tax Services – Foreign Investors

    Our multilingual international tax advisors will help foreign investors structure their U.S. investments or activities so they can minimize their taxes and assure a higher rate of return on their investment. We will help foreign investors choose the appropriate entity for their business by taking into consideration their worldwide situation and long-term goals. Additionally, we also provide pre-residency tax planning for foreign individuals who want to move to the United States and assist them in understanding and navigating the complexities of the U.S. tax system.

  • U.S. Outbound Tax Services – U.S. Investors

    For U.S. persons investing overseas, the tax laws and regulations are very complex and extremely regulated. The form of entity in which a U.S. person does business or invests overseas will have dramatic tax consequences on the business or investment, as well as create certain additional reporting requirements in the United States. U.S. persons that own foreign profitable operating businesses through foreign corporations can generally defer paying U.S. taxes on income earned abroad until that income is repatriated to the United States. However, anti-deferral provisions exist that may eliminate the benefit of deferral for passive income. We provide a wide range of international tax consulting and compliance advice on foreign investments to help clients achieve their objectives.

  • Expatriate Tax Advisors

    In the broadest sense, a U.S. expatriate is a U.S. person living and working in a country other than the United States. Expatriates are subject to U.S. tax on their worldwide income and, as such, must file a U.S. tax return while living abroad. However, an expatriate may be able to reduce U.S. taxable income by claiming foreign earned income and housing exclusions. Expatriates can also reduce U.S. tax liability through the use of foreign tax credits. Our expatriate tax services include a range of income tax compliance and advisory services related to long-term assignments or permanent relocation outside the United States.

  • International Tax Solutions

    Hernandez & Company International Tax Advisors have extensive experience in international taxation. Drawing on our extensive experience and taking into account each client’s specific business goals and objectives, we are able to customize and implement investment-driven structures to meet their changing needs. We will help you comply with complex international tax laws and regulations. We can be your private individual tax advisors, or we can act as your U.S. subsidiary tax department.

Serious Tax Advisors for Serious Investors

U.S. Inbound Tax Services

Expanding your business to the United States or investing in the United States requires thorough and careful planning, especially when it comes to complex U.S. tax laws and regulations. Hernandez & Company has over 20 years of experience in advising foreign investors in all tax aspects of their United States investment or business activities. We carefully analyze each client’s situation and, if necessary, coordinate with their tax advisors in their home country to create a strategy to minimize their global effective tax rate. Whether you are planning to open a business or invest in the United States, our dedicated international tax advisors can help you with:

  • Choosing the optimal entity structure for U.S. businesses or investments.
  • Pre-residency tax planning and inbound transaction planning.
  • U.S. federal and state income tax return preparation for corporations, individuals and trusts
  • U.S. estate and gift tax returns for foreigners with United States assets
  • Income, sales and payroll tax compliance for businesses operating in the U.S.
  • Assistance with multinational branch profits tax
  • Transfer pricing planning and documentation
  • Certificate of foreign person’s claim that income is effectively connected With U.S. trade or business
  • Annual withholding tax return for U.S. source income of foreign persons
  • Foreign person’s U.S. source income subject to withholding
  • Treaty-based return position disclosure
  • Closer connection exception statement for Aliens
  • Statement for exempt individuals and individuals with a medical condition
  • FIRPTA – Application for withholding certificate for dispositions by foreign persons of U.S. real estate property
  • Information return for a foreign-owned U.S. Corporation or a foreign corporation engaged in a U.S. Trade
  • Certificate of foreign status of beneficial owner for United States tax withholding
  • Annual return for partnership withholding tax
  • Application for United States residency certification
  • Applicability of tax treaty provisions
  • Translation of tax forms into English for 37 countries
  • Repatriation planning and reporting

One Stop Solution to Manage your U.S. Operations

It is not cost effective for a U.S. subsidiary of a foreign company to have a full-time tax department or even a full-time tax professional. Our international tax advisors currently assist over 500 subsidiaries of foreign companies with U.S. tax compliance. Hernandez & Company can assist you with all your international accounting and tax needs. We will perform a detailed assessment of internal tax issues related to your specific operations and make sure you stay up to date on new tax, legislative and regulatory developments.

    U.S. Outbound Tax Services

    For U.S. persons investing overseas, the tax laws and regulations are very complex and extremely regulated. As investors and multinationals expand globally, they are faced with the complexities of multi-jurisdictional taxation. To remain competitive and in compliance with tax laws, they will need to examine the tax implications of their business and investment strategies in each jurisdiction where they plan to invest or conduct business. Whether you are planning to open a business or invest overseas, our dedicated international tax advisors can help you with:

    • Choosing the optimal entity structure for foreign businesses or investments from a U.S. tax perspective
    • U.S. tax deferral planning by using the most tax efficient type of structure
    • U.S. federal and state income tax return preparation for corporations, individuals and trusts
    • Foreign tax credit planning and consulting
    • Transfer pricing planning and documentation
    • Income sourcing and allocation and apportionment of expenses
    • Optimization of gains and losses from foreign currency transactions
    • Assistance in the acquisition and/or sale of foreign businesses
    • Information return of U.S. taxpayer (officer/director/owner) with respect to certain foreign corporations
    • Information return of U.S. taxpayer with respect to certain foreign partnerships
    • Information return of U.S. taxpayer with respect to certain foreign disregarded entities
    • FATCA – Filing of mandatory statement of specified foreign financial assets
    • FBAR – Report of Foreign Bank and Financial Accounts
    • Report transactions with foreign trusts and receipt of certain foreign gifts
    • Initial and annual expatriation statement
    • U.S. departing Alien income Tax Return
    • Assistance with IRS “amnesty” programs
    • Applicability of tax treaty provisions
    • Translation of Tax forms into English for 37 countries
    • Repatriation planning and reporting

    Helping You Stay in Good Standing

    A U.S. person who plans to invest or conduct business through an entity outside the United States should be aware that the Internal Revenue Service is increasing its scrutiny of taxpayers who have or control foreign financial accounts, including bank accounts and investment accounts, or who have failed to disclose interests or report income from foreign corporations, partnerships, gifts, trusts, or estates. Taxpayers who fail to properly disclose foreign investments or assets risk significant civil and criminal penalties. (Civil penalty equal to the greater of $100,000 or 50% of the balance in the foreign account) + (Criminal Penalties – prison terms of up to ten years and criminal penalties of up to $500,000)

    Hernandez & Company can assist you with all your international accounting and tax needs. Our typical outbound clients include U.S. persons investing abroad, foreign investors who became U.S. residents, law firms that specialized in international taxation and other local CPA firms who do not have expertise in international taxation. In addition, we assist Banks with the translation of foreign tax forms into English for their international clients. Our international tax advisors can perform a detailed assessment of internal tax issues related to your specific operations and make sure you stay up to date on new tax, legislative and regulatory developments.

      Expatriate Tax Advisors

      The increasingly integrated global economy has made international tax planning a key strategy for individuals and organizations working overseas. As a U.S. citizen or resident alien, you are subject to U.S. income tax on your worldwide income, even if you are living abroad. Also, you are subject to the same income tax filing requirements that apply to U.S. citizens or residents living in the United States. The good news is that you may qualify for the foreign earned income exclusion, foreign housing exclusion, income tax credits, and other benefits if you meet certain requirements.

      We specialize in expatriate tax services for U.S. persons that live and work around the world. Our Expatriate Tax Advisors handle all tax issues related to living abroad for both temporary and long-term assignments, and permanent transfers. We can help you minimize your global tax obligations and meet your tax-compliance responsibilities while you are away. We have established working relationships with accounting, law, and consulting firms in more than 50 countries.

      Expatriate Tax Services:

      • Pre-departure and post-assignment tax consultations
      • US federal and state income tax return preparation
      • Assistance with inquiries from U.S. and foreign taxing authorities
      • Calculation and coordination of estimated tax payments
      • Help with complex international social security rules
      • Foreign earned income exclusions calculation
      • Foreign tax credits and deductions calculation
      • Foreign housing exclusion
      • Self-employment tax planning
      • Extensions for filing U.S. Tax Returns
      • Reporting foreign bank accounts (FBAR)
      • Applicability of tax treaty provisions
      • Assistance with IRS “amnesty” programs

      Employer Expatriate Tax Services:

      • Structuring tax-effective assignment terms and compensation packages
      • US federal and state income tax return preparation
      • Calculation and coordination of U.S./foreign estimated tax payments
      • Assistance with inquiries from U.S. and foreign taxing authorities
      • Social security tax planning and payroll consulting
      • Controlled foreign corporations (CFC)
      • Foreign tax credit planning and consulting
      • Applicability of tax treaty provisions
      • Translation of Tax forms into English for 37 countries

      Delivering Global Solutions for US Expatriates

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