
provides the following client services:
Form 5471
IRS Roadmap for Transfer Pricing and
Foreign Tax Credits. Preparation/review of “Information Return of U.S. Persons With
Respect To Certain Foreign Corporations,”
including U.S. shareholder, offi cer or director
reporting, Earnings and Profi ts calculations
and Schedule M for inter company
transactions.
Transfer Pricing
Preparation/review of written documentation,
reports, and the impact on the income tax
provision to comply with the new FIN 48
reporting requirements.
FIN 48 Compliance
The new financial statement reporting
requirement for years beginning after
December 15, 2006 will entail a detailed
review of certain tax benefits recorded
that have less than a 50% chance of being
sustained.
Income Tax Provision
Preparation/review of quarterly or year-end
income tax provision, deferred taxes, required
tax footnote disclosure, including the tax rate
reconciliation.
Foreign Dividend Planning
Preparation/review of foreign Earnings and
Profi ts calculations, related expenses under
Section 861-8 of the income tax regulations
for optimal payment date and maximization
of Federal Tax Credit.
Tax Audit Support
U. S. and Foreign Data collection,
preparation/review of submissions to the tax
authorities, and explanation of various tax
consequences of submissions.
Mergers and Acquisitions
Review/planning related income tax activities
connected with the transaction or proposed
transaction, including review of documents,
entity structuring, U.S. and foreign tax issues
and due diligence reviews.