Tax Services

International Tax Planning for Cross-Border Businesses

CPA-led international tax strategy for companies operating across borders — foreign company formation, transfer pricing documentation, and base erosion (BEAT) planning. We help California businesses structure global operations correctly, stay compliant with IRS reporting, and avoid the costly penalties that come with cross-border missteps.

Schedule an International Tax Consultation (951) 216-3121

Cross-border business creates some of the most complex and most penalized areas of the tax code. A foreign subsidiary, an overseas contractor, or intercompany sales between related entities all trigger U.S. reporting requirements that carry steep penalties for getting them wrong — often $10,000 or more per missed form. Transfer pricing rules require documented, arm's-length pricing between related companies. The base erosion and anti-abuse tax (BEAT) can apply to payments made to foreign affiliates. Without a CPA who understands international structure, businesses either overpay or expose themselves to serious compliance risk.

What Is Included

What You Get With International Tax Planning

Foreign Company Formation and Structure

We advise on the right structure for foreign operations — subsidiary, branch, or holding company — coordinating U.S. and foreign tax treatment, treaty benefits, and the entity classification (check-the-box) elections that shape your global tax position.

Transfer Pricing Documentation

When related entities transact across borders, the IRS requires arm's-length pricing with supporting documentation. We help establish defensible transfer pricing policies and the contemporaneous documentation that protects you in an examination.

Base Erosion (BEAT) Analysis

We evaluate exposure to the base erosion and anti-abuse tax on payments to foreign affiliates, model its impact, and structure intercompany arrangements to manage liability while staying fully compliant.

Cross-Border Compliance and Reporting

We handle the international information returns that carry the heaviest penalties — Forms 5471, 5472, 8865, 8858, and FBAR/FinCEN reporting — so foreign ownership and intercompany activity are reported correctly and on time.

GILTI and Subpart F Planning

For owners of controlled foreign corporations, we analyze GILTI and Subpart F income inclusions, the related elections and credits, and structure that minimizes the U.S. tax cost of foreign earnings.

Foreign Tax Credit Optimization

We coordinate foreign taxes paid with U.S. liability to claim the foreign tax credit efficiently, avoid double taxation, and apply treaty provisions that reduce withholding and overall global tax.

Who We Serve

Is This Service Right for You?

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Businesses Expanding AbroadU.S. companies setting up a foreign subsidiary, branch, or operation who need the structure and reporting done correctly from day one

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Foreign-Owned U.S. CompaniesBusinesses with foreign ownership or foreign affiliates facing Form 5472, transfer pricing, and BEAT requirements

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Companies With Intercompany TransactionsRelated entities buying, selling, licensing, or lending across borders who need defensible arm's-length pricing

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Owners of Foreign CorporationsU.S. taxpayers with controlled foreign corporations navigating GILTI, Subpart F, and the international information returns

Common Questions

International Tax FAQ

Transfer pricing is the price charged between related companies for goods, services, or intellectual property crossing borders. The IRS requires these prices to reflect what unrelated parties would charge — the arm's-length standard — and requires documentation to support them. Getting it wrong can shift income improperly and trigger adjustments, penalties, and double taxation, which is why contemporaneous documentation matters.

The base erosion and anti-abuse tax (BEAT) is a federal minimum tax aimed at large companies that reduce their U.S. taxable income through deductible payments to foreign affiliates. It applies above certain size thresholds. Even if you are below them today, understanding BEAT matters when structuring intercompany payments as you grow. We model exposure and structure arrangements to manage it.

International information returns carry some of the steepest penalties in the tax code — commonly $10,000 or more per form, per year, even when no tax is owed. Forms like 5471, 5472, 8865, and FBAR all have their own requirements and deadlines. We make sure foreign ownership, accounts, and intercompany activity are reported correctly so these penalties never apply.

Structure Globally, Compliantly

Get Cross-Border Tax Right the First Time

International structure is expensive to fix after the fact. Start with a consultation and build it correctly from the start.

Schedule a Consultation (951) 216-3121