Many companies require a complex set of data to execute transactions that can significantly impact global tax liability. Although we do not engage in the business of providing tax planning advice, we are focused on providing relevant data for tax planners so that effective tax planning and execution can be accomplished. Whether a company is in the process of executing key international tax processes such as tax provision, tax compliance or tax planning, lack of supportable data can hinder successful analysis and the completion of a project.
We have produced the best international tax software in the industry based on its collective experience dealing with complex quantitative issues. The same group of tax professionals, who inspired and designed the international tax software, now provide a quantitative analysis service.
Most quantitative analyses are difficult because of the poor quality of data to support complex calculations, as well as the lack of tools to organize the data and perform the necessary calculations. For example, in order to perform adequate earnings and profits analysis, a company must have historical financial data, organizational structure data, corporate transactions, and details of tax positions as a basis for the analysis. Additionally, a complex calculation tool that can perform multi-year computations with dynamic intercompany transactions (look-through) for large number of entities is necessary. Such a tool must be able to handle multiple currency translations, currency conversions, movement of E&P due to corporate transactions, and perform all international tax rules (Subpart F Income rules, distribution rules, other deemed distribution rules, historical data maintenance rules) with different tax rules applied to different tax years. It is impossible to perform calculations as complex as U.S. international tax rules in any spreadsheet without some degree of failure.
We have the technology to collect and organize large volumes of unstructured data, the software to execute complex calculations, and the experienced professionals capable of completing the project in such a way that it delivers an organized set of information to support transactions. We also deliver the process analysis based on the project content and the means by which individuals can update the data. By the end of the process, everyone will possess the knowledge necessary to improve the process of maintaining and updating data in the future.
Our quantitative service includes the following:
- Foreign tax credit analysis
- Historical attribute analysis
- §861 analysis (interest, R&D, and so forth)
- OFL analysis
- FTC attribute analysis
- Planning analysis (quantifying the effects of proposed planning)
- Global structure planning support
- Check-the-box planning
- Partnership planning
- Asset allocation planning
- Repatriation planning
- Historical entity attribute analysis
- E&P study
- §1248 analysis
- Basis study
- Basis study
- Compliance attribute analysis
- §987 analysis
- Provision attribute analysis
- Deferred items analysis
- Tax account reconciliation
- Return to accrual (true-up) analysis
- Litigation support
- IRS audit
- Global attribute allocation analysis