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international tax planning

International Tax

The business world has become a level playing field, giving companies everywhere new global opportunities to expand and branch out. FGMK helps you manage the international tax challenges that arise when you go global.

FGMK assists global companies and their owners in navigating the complex field of international taxation and optimizing their after-tax operating results. We recognize that business goals must drive tax planning, and we partner with our clients to achieve their goals. Our tax professionals will help you ensure that your business adheres to the tax laws of each country in which you operate. We bring in-depth and up-to-date knowledge of international tax rules to help you streamline and manage your tax processes more effectively.

Michael R. Pearson


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We partner with our clients to achieve their goals.

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FGMK regularly engages with our clients in:

  • Assisting with FDII opportunities
  • Evaluating GILTI impacts and structuring alternatives
  • Foreign tax credit planning
  • Optimizing the results of export sales through the use of the IC-DISC tax incentive and other available planning techniques
  • Planning for foreign joint ventures, joint investments and mergers & acquisitions
  • Planning for tax-efficient cross-border transaction structures
  • Planning, structuring and documenting transfer pricing arrangements between the US parent and foreign related parties
  • Planning with respect to “Subpart F” and other US anti-deferral tax legislation
  • Repatriation planning


FGMK works with international companies doing business in the US, and helps manage their US tax exposure. Our services include:

  • Assisting with FDII opportunities
  • Evaluate US entity structuring alternatives
  • Compliance and reporting for US branch or subsidiary operations
  • Inbound investment and transaction structuring
  • Management of anti-conduit financing and anti-earnings stripping rules with respect to inbound financing
  • Management of withholding tax costs
  • Optimization of tax treaty benefits
  • Planning, structuring and documenting transfer pricing arrangements between the foreign parent and the US related parties
  • Structuring for US real property investments
  • US “trade or business” / Permanent Establishment risk mitigation


Once your international transactions and structures are in place, you will need to comply with tax and other reporting requirements. Meeting those requirements ensures the preparation of accurate income tax returns and increases the likelihood of success in the event of an IRS audit. FGMK will support your reporting requirements, including:

  • Applications under the IRS Offshore Voluntary Disclosure Program and the Streamlined Foreign and Domestic Offshore Programs
  • Assisting with expat compliance, forms 1040NR, 2555, etc.
  • Assisting with forms 8992 and 8993 compliance (GILTI and FDII)
  • FATCA entity and payment analysis and related compliance
  • Foreign bank account and asset reporting
  • Foreign earnings and profits (E&P) calculations
  • Foreign tax credits
  • IC-DISC computations and reporting
  • Section 367 outbound and foreign-to-foreign transfers

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