Tax Accounting & Consulting

International Tax Services & Planning

If you are planning on an international move and/or expanding your business beyond your country's borders, then you are facing many complex and far-reaching international tax planning questions. Our international tax professionals have the experience to help you answer your questions and address other international tax issues you may not have considered, to ensure that your plans are tax efficient, and support your business and personal goals.

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Our Approach

Team With International Exposure

In addition, our professionals speak the following languages:

  • Afrikaans
  • Arabic
  • Bulgarian
  • Cambodian
  • Chinese (Cantonese
    & Mandarin)
  • Croatian
  • Farsi
  • French
  • Gaelic
  • Hindi
  • Indonesian
  • Italian
  • Japanese
  • Korean
  • Portuguese
  • Punjabi
  • Russian
  • Serbian
  • Spanish
  • Tagalog
  • Taiwanese
  • Vietnamese
  • U.S. Businesses that have foreign operations or are planning to expand internationally
  • Foreign Businesses that have U.S. operations, U.S. source income or who are planning to enter the U.S. marketplace
  • U.S. High-Net-Worth Individuals with foreign source income or who are or plan on working/residing outside of the U.S.
  • Foreign High Net Worth Individuals with current U.S. business/investment activities or who plan on moving to the U.S.
  • U.S. or Foreign Employers who have employees working outside their home country

Our international tax services for the individuals and employers listed above include:

  • International business consulting and structuring – Our experts will assist you in structuring your business in compliance with international transparency, social responsibility and corporate governance guidelines.
  • International tax compliance – Our customized tax compliance services offer you a flexible, scalable way to navigate the complex environment of international tax.
  • Voluntary compliance – We offer programs for you to review your international tax compliance for foreign financial accounts and assets.
  • IP migration services – U.S. companies that create, develop and sell intellectual property (IP) often find it financially advantageous to transfer their intangible assets to foreign countries offering attractive incentives and tax rates. Our international tax services will help ensure that the sale and use of IP in foreign countries is transparent and tax efficient.
  • Transfer pricing management – Tax authorities around the world are focusing more and more attention on transfer pricing issues. We provide tailored transfer pricing solutions to fit your specific business needs.
  • International provision (FAS109) work (financial statement support) – Our international tax experts will help you assess your assets and liabilities for income tax reporting.
  • “Back office” services for foreign startups entering the U.S. – Foreign leadership teams may not be familiar with the particulars of U.S. finance, accounting and human resources requirements. Armanino provides a full range of back office services, so business leaders can focus on creating value.
  • International M&A work – Armanino can help you navigate the legal, regulatory, tax, accounting, governmental and cultural issues inherent in global mergers and acquisitions.
  • U.S. market entry consulting and pre-immigration planning.
  • “Expat” tax compliance, tax equalization calculations and compensation planning.
  • International estate tax planning – Multiple jurisdiction estates require careful planning. Our international tax experts will help you navigate the complexities of reporting and paying taxes in multiple countries, reducing your tax burden as you pass along your estate to your heirs.
  • Filing of BEA Form BE-10 – We can file the Bureau of Economic Analysis (BEA) Form BE-10 for U.S. persons with non-U.S. investments. It's due every five years.
  • Coordination with professional service firms (e.g., immigration, translation, customs, banking, etc.).
  • Issuance of individual taxpayer identification number (ITIN) – You no longer have to go through the trouble of going to your country’s consulate or embassy to have your documents certified.

We help you simplify your life and grow your business.

Global Expansion: Top Tax Considerations
White Paper
Global Expansion: Top Tax Considerations
CFOs must navigate the complexities of international growth while also managing huge shifts in U.S. tax laws. Businesses that adapt quickly to this new reality will gain ground on their competitors.

Our team has served many prominent multinational clients, providing tailored transfer pricing solutions based on their needs. We approach every project in a consultative and collaborative manner, with the goal of helping you reduce risk by establishing economically supportable and practical transfer pricing policies.

Our membership in Moore Global Network allows us to examine your transfer pricing issues from all angles with assistance from our partner firms across the globe. Moore Global has offices in more than 100 countries, so wherever your issues arise, we have experts who can help.

Transfer Pricing Services

Policies and Processes Consulting

Transfer pricing can be a very complicated endeavor. We provide tax and consulting services to help you build, manage, document, review and defend your transfer pricing policies and processes.

  • Planning: To succeed globally, you need to develop economically sound and sustainable transfer pricing policies. Our experts can provide transfer pricing advice for all types of planning arrangements, including services, tangible and intangible assets transferred during a business restructuring, financial transactions and licensing.
  • Compliance and Documentation: We prepare documentation studies and pricing analyses for all types of transactions, including tangible and intangible goods transactions, intercompany service transactions, cost-sharing arrangements and financial transactions for U.S. and foreign compliance purposes.
  • Policy Design and Implementation: We can help you develop and implement policies and procedures for setting, monitoring and documenting intercompany tax transactions.
  • Financial Statement Support Services: We have extensive experience assisting companies with the preparation of alternative tax positions for FIN 48 analyses and relevant supporting memorandums.
  • Tax Controversy and Dispute Resolution: Our team can help resolve transfer pricing disputes through various services, including avoidance techniques, resolution alternatives, strategic planning, risk management, analysis and disclosure.
Moore Global Network

Moore Global Network

Armanino is a member of Moore Global Network, one of the largest international networks of firms in the world. This network provides us, and by extension, our clients, with resources on the ground in nearly every corner of the globe, as well as local knowledge on legal and tax issues for various jurisdictions.

Moore Global
GILTI, FDII and BEAT: What They Mean for U.S. Multinationals
GILTI, FDII and BEAT: What They Mean for U.S. Multinationals
There have been significant changes to the way the U.S. taxes multinational earnings, especially if the company is based in the U.S.
Nghi Huynh - Partner, Tax - San Jose CA | Armanino
Nghi has more than 16 years of experience in transfer pricing, tax planning projects, research and audit.

San Jose, CA
Jon Davies - Partner, Tax - San Jose CA | Armanino
Jon specializes in international tax structuring, cross-border transactions, transfer pricing, and merger acquisition.

San Jose, CA
Ken Harvey - Tax
Ken has more than 30 years of experience as an international tax advisor, focusing on international tax structuring.

San Jose, CA
International Tax Accounting News & Tips
Tllray 382
Case Study
Here’s how one loss corporation was able to offset $64M of taxable income with help from our Section 382 experts.

March 14, 2022
SaaS Company Reduces International Taxes With Revised Transfer Pricing Method
Case Study
The new tax methodology solved challenges in foreign distribution entities and provided earnings predictability.

December 22, 2021
Regulatory and Industry News Alerts from Armanino
The guidance impacts taxpayers that have not been sharing stock-based compensation in their cost-sharing arrangements.

August 05, 2021
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