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Marcum LLP
Marcum LLP
Tax & Business

International Taxation

Three Men Standing

The Marcum 2016 Year-End Tax Guide continues our tradition of providing timely tax guidance for the upcoming year.


Marcum LLP's International Tax Services Group assists companies that are expanding their operations internationally.

Whether that means a move or expansion into or out of the United States, for operations or personnel, expert advice is crucial. Our International Tax Services Group has the extensive expertise and the technical knowledge to assist in structuring transactions worldwide. The Firm works closely with our international affiliates to assist clients by minimizing their overall tax burden while coordinating tax planning and compliance services.

Our professional staff is augmented by our relationship with Leading Edge Alliance, an affiliation of leading regional public accounting firms in major cities throughout the world. In addition, Marcum offers extensive global resources as the exclusive U.S. member firm of ECOVIS International, an accounting and advisory network with members in 60 countries on six continents.

Contact one of Marcum's regional representatives.


Related Services:     International Taxation   |   Transfer Pricing   |   International Individual Mobility Services
International Tax Planning Consulting Services

Our team provides professional tax planning and consulting services in connection with the following:

Businesses and Entities

  • Optimization of structures for foreign investment and business operations in the U.S.
  • Optimization of structures for U.S. investment and business operations outside of the U.S.
  • Structuring for cross-border acquisitions, sales and other exchanges.
  • Structuring for acquisition, operation and disposition of U.S. real estate.
  • Controlled foreign corporation issues.
  • Interest Charge Domestic International Sales Corporations (IC-DISCs).
  • Passive Foreign Investment Company issues (PFICs).

Individuals and Trusts

  • U.S. executives working and residing overseas.
  • Foreign executives working and residing in the U.S.
  • Tax issues for non-citizens immigrating to the U.S.
  • Tax issues for individuals considering expatriation from the U.S.
  • Gift, trust and estate considerations for non-citizens with U.S. based assets.
  • U.S. beneficiaries of foreign trusts.

Other Matters

  • Income tax treaties and totalization agreements.
  • Foreign tax credits.
  • Subpart F and other anti-avoidance rules.
  • Tax aspects of foreign currency exchange.
  • Matters related to payments of U.S. source income to foreign persons.
Transfer Pricing

Our team works with multinational companies to define, manage and plan for transfer pricing. Our services include the preparation of domestic and worldwide documentation designed to comply with local requirements, assistance with the alignment of tax planning objectives and business objectives, and assistance with the assessment and management of tax risk.

Outsourced International Tax Director Services for Companies and Global Families

Our team provides outsourced services to companies that can benefit from having a part-time international tax director.

The need may be short term, such as in the event of an acquisition or disposition that temporarily increases workload beyond what can be comfortably handled by internal resources, or due to the need for a temporary replacement of a resource that is on vacation or other type of leave. Alternatively, the need may be long term due to a regular and continuous need for a sophisticated resource to assist with periodic international tax issues, but where the need requires less than full-time attention.

Our professionals provide hands-on services to help companies focus on international tax planning opportunities and compliance matters. Additionally, we can assist global families with the management of U.S. based investments, U.S. trust matters and overall financial planning objectives to meet their respective needs.

International Taxation Brochure

Withholding Tax Services

Our team provides advice to companies and individuals regarding issues related to withholding and reporting compliance, including:

  • U.S. withholding and reporting for payments made to foreign persons.
  • Use of Qualified intermediaries.
  • Foreign withholding tax matters.
  • Application of income tax treaties to amounts subject to withholding at source.
  • Application of U.S. withholding rules to offshore withholding agents.
  • Backup withholding matters.
Withholding Tax Services
Expatriate and Impatriate Tax Services

Our team provides tax planning and compliance services to U.S. executives on assignment overseas and their U.S. employers, as well as to foreign executives on assignment in the U.S., including:

  • Consultation to foreign nationals and U.S. citizens living abroad with the objective of providing solutions to minimize taxes worldwide, including through the application of income tax treaties and social security totalization agreements.
  • Preparation of U.S. income tax returns and other required filings for individuals with cross-border tax issues.
  • Consultation to companies with executives on overseas assignment (inbound/outbound), including assistance to human resource and payroll personnel.
  • Assistance with the calculation of gross-ups of foreign assignment allowances, tax equalization computations, and appropriate actual and theoretical withholdings.
Expatriate and Impatriate Tax Services
U.S. Tax Compliance

Our team provides a wide variety of tax compliance and preparation services related to foreign and international tax reporting, including:

  • General compliance services for U.S. corporations and individuals with foreign based businesses and investments.
  • Preparation of and assistance with data gathering for U.S. international tax forms (1118, 5471, 8865, 8858, 5472, 1120-F).
  • Quantitative services related to U.S. international tax calculations (foreign tax credit, Subpart F, section 956, earnings and profits).
  • Accounting and tax preparation services for foreign nationals and foreign owned businesses.
  • Withholding tax returns for U.S. payers to foreign persons.
  • Assistance with U.S. individual tax identification numbers.
  • Income tax services for U.S. individuals with beneficial interests in foreign trusts.
  • Estate tax returns for nonresident aliens.
Related International Taxation News

New Reporting Requirements by Foreign-Owned U.S. Disregarded Entities


The IRS has recently issued final regulations regarding the treatment of U.S. disregarded entities wholly owned by foreign persons. These final regulations became effective December 13, ....

Bloomberg BNA's Daily Tax Report quoted Tax Partner Elizabeth Mullen in an article about transfer pricing controversies currently pending before the U.S. Tax Court.


Some of the best-known companies in the U.S. and the world dispute the IRS’s characterization of expenses they can deduct from transactions with their foreign ....

Tax Partner John Mezzanotte spoke with BioSpace about international tax considerations for pharma companies.


Taxes were a heated issue during this year’s presidential election, and now, as President-elect Donald Trump rolls out his proposed tax plan, promising the largest ....

Treasury Issues Final Section 385 Regulations on Reclassification of Related Party Corporate Debt


On October 14, 2016, the U.S. Treasury Department issued final regulations addressing whether an interest in a corporation is to be treated as stock or ....

Marcum LLP Named Exclusive U.S. Member Firm of ECOVIS International


Marcum LLP has been named the exclusive U.S. member firm of ECOVIS International, a global accounting and advisory network with members in 60 countries on six ....

Apple and Transfer Pricing Turmoil


The European Union's ("EU") antitrust regulator, the European Commission ("Commission"), has changed the way the world looks at transfer pricing and tax favored regimes. Asserting that ....

IRS Proposes New Qualified Intermediary Agreement


The IRS released Notice 2016-42, outlining the proposed new Qualified Intermediary (QI) agreement under FATCA rules, in July 2016. The draft agreement highlights significant updates ....

OVD Initiative Update: When is "Streamlined" NOT so Streamlined?


Since 2012, 30,000 Americans avoided stiff tax penalties by declaring they had innocent reasons for failing to disclose offshore holdings.

New Regulations Tighten Rules on Foreign Investors' U.S.-Sourced Dividends


On September 17, 2015, the Internal Revenue Service (the "IRS") issued final regulations under Code Section 871(m) relating to the imposition of U.S. withholding tax ....

Reporting Offshore Financial Accounts: The Costs of Non-Compliance


As a general rule, the United States taxes its citizens and residents on their worldwide income and imposes annual information reporting on certain foreign assets. ....

Recent U.S. International Tax Development: The PATH Act


On Friday, December 18, President Obama signed the Protecting Americans from Tax Hikes Act of 2015 ("the PATH Act") which provides more certainty for international ....

FBAR Due Date Moves Up to April 15th


On July 31st, President Obama signed the ‘Surface Transportation and Veterans Health Care Choice Improvement Act of 2015' into law, which as unlikely as the ....

FBARs Another Deadline Approaches - New Guidance


As we approach June 30, we are reminded, again, that any U.S. person who has a financial interest in or signature authority over any foreign-based ....

Upcoming Filing Deadline - May 29th Due Date for U.S. Persons with Foreign Affiliates


Pursuant to the requirements of the International Investment and Trade in Services Survey Act and related statutes, the U.S. Department of Commerce's Bureau of Economic ....

Expatriates Running out of Time to Avoid IRS Penalties

United States citizens (and green card holders) residing outside the U.S. often lose sight that they are required to file an annual income tax return ....


Beyond the Numbers

Roundup of business and tax planning ideas



Select the region to view contacts.

Mark Chaves

Tax & Business
Miami, FL
Douglas Nakajima

Tax & Business
Philadelphia, PA



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