International Tax Services

"Whether you are outsourcing manufacturing operations to Asia or seeking investors from Europe, we have a tailored tax solution to address your cross-border tax requirements."

In today's global economy, it is not uncommon for U.S. and foreign taxpayers to venture abroad for business opportunities. Often times these taxpayers find the U.S. income tax rules relating to their international transactions to be complex and full of surprising pitfalls. RINA provides international tax expertise through a combination of Big 4 and regional firm experience to help taxpayers navigate these rules.

The U.S. tax authorities adopt a hybrid approach to international taxation. In regards to taxation of U.S. person's foreign activities (also known as "outbound" transactions), the U.S. adopts a residence-based taxation system. In other words a U.S. person is subject to U.S. federal income tax on the person's worldwide income regardless of the source of such income.

In regards to taxation of foreign person's U.S. activities (also known as "inbound" transactions), the U.S. adopts a source-based taxation system. Therefore a foreign person will generally be subject to U.S. income tax only on U.S. source income and not on the person's worldwide income.

At RINA, we specialize in the following international tax issues:

• Constructive dividend/Subpart F income analysis
• Selection of the most tax-efficient entity for foreign operations
• Income tax treaty analysis
• U.S. income tax impact pertaining to foreign taxpayers operating in the U.S.
• Tax-efficient use of debt versus equity in capitalizing operations
• Transfer pricing issues involving related taxpayers
• Export incentives such as exporting through an IC-DISC
• U.S. income tax compliance relating to international transactions

Through our affiliation with MGI, an international accounting association of independent professional service firms, we have access to the local knowledge of tax professionals in over 280 offices throughout 80 countries.

For more information about our services, contact:

Tom Neff, Stockholder
tneff@rina.com


Brenda Jemmott, Manager
bjemmott@rina.com