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Understanding International Tax

Looking to expand globally? We can help.

INTERNATIONAL TAX

Going global can be a daunting challenge for small companies. Yet today, the ability to get your products to customers overseas or in other countries is easier than it may seem. Are you manufacturing offshore? Selling overseas? What are the tax implications both domestically and abroad?

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IC-DISC Formation and Optimization

Manufacturing products in the U.S. and selling outside of the United States

IC-DISC or Interest Charged-Domestic International Sales Corporation is a separate US entity formed to allow US exporting companies (including both manufacturers and distributors) to eliminate income taxes based upon their international sales. Formed and regulated under the Internal Revenue Code (Sections 991-997), an IC-DISC takes advantage of current dividend rates and can provide additional working capital to US manufacturing companies through a 20% permanent tax savings.

Does your company:

Manufacturing products in the United States?

Selling products or services to customers located outside the United States?

Acena Consulting provides both IC-DISC Formation and Optimization services. Because the tax regulations regarding the way companies can calculate the potential savings available are highly technical, utilizing Acena Consulting to maximize the potential savings can be dramatic.

Learn some basics of IC-DISC with our free slides:

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Transfer Pricing: Section 482

Transfer pricing refers to the pricing and movement of expenses within an organization

When one division (or subsidiary) of a company transfers goods or services to another division (or subsidiary) within their company, these goods and services are transferred at a certain price. If these two divisions (or subsidiaries) are in different countries, the price at which goods and services are transferred will impact the amount of taxable income in each country. Because this situation can result in shifting net income and profit, as well as taxes due between countries, many countries have adopted tax policies to review and assess penalties if it appears a company has attempted to transfer costs to tax havens (countries with lower tax rates). Today, most countries have adopted tax laws utilizing the arm’s length principle defined by the OEDC (Organization for Economic Co-operation and Development ).

Acena Consulting can help companies to complete a Transfer Pricing study to analyze their inter-company transactions and pricing policies. Our team of economists and former “Big Four” professionals bring a wealth of experience to benefit our clients.

Download our IC-DISC IRS Audit Technique Guide:

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Transfer Pricing Studies & Support

In addition to being an international tax issue, transfer pricing is becoming a larger issues between states.

Demonstrating arms-length transactions between related entities either domestic or internationally is critical to successfully defending your company against a state of federal tax audit. Our team of international tax experts include former "Big 8" partners who have worked with both Fortune 100 companies and small growing organizations beginning to operate in a global market. Today, more than 60 governments have implemented transfer pricing rules most of which follow the OECD definition of an arms length transaction (notable exceptions include Brazil and Kazakhstan).

Our services include:

IRS and state audit support in the event of an audit Unilateral and bilateral

Advanced Pricing Agreements

Federal and state pricing documentation

Cost sharing agreements between related parties

Tax Treaty review and analysis

Transfer Pricing Strategy consulting

FIN48 support & analysis Intangible valuations and analysis

Global documentation design and development

Assistance with best practices development and implementation

Contact Acena Consulting today to assist you with any of your IC-DISC needs:

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Testimonials

See what people are saying about us

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"Efficient and Knowledgeable. Randy Eickhoff & Acena Consulting have always provided proactive, efficient and responsive service. In addition to their strong technical expertise, they bring new opportunities for additional tax savings that apply to our company. We appreciate their ability to be flexible to work within our culture to best fit our needs." -H.S., CEO, Fast Growing Technology Co. Scottsdale, AZ

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