Ryan E. Miller


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International Tax


It’s a global economy. Suppliers – as well as customers – are continually extending overseas, and more initiatives are being outsourced internationally. Katz, Sapper & Miller understands navigating the waters of rapidly changing international tax planning and compliance can be complex. We have the experience you need to not only find your way, but to achieve even greater success.

Our firm is uniquely positioned to provide international tax planning services to closely held multinational businesses. In fact, the tax structure that may be best suited for these types of operations is generally very different from the structure utilized by larger operations. Our professionals know the planning opportunities that are presented by these differences, including:

  • Transfer pricing issue spotting
  • Entity classification elections
  • Efficient utilization of foreign tax credits
  • Maximizing benefits from international tax treaties
  • Minimizing withholding obligations
  • Identification of deferral opportunities
  • Cross-border mergers and acquisitions
  • IC-DISC planning for U.S. exporters
  • Calculating and minimizing the impact of GILTI

Katz, Sapper & Miller can also provide international tax planning services to C Corporation structures. In addition to the planning opportunities discussed above, our areas of expertise unique to C Corporations include:

  • Subpart F planning and calculations
  • PFIC planning and calculations
  • Earnings and profits determinations
  • Repatriation planning
  • Deemed paid foreign tax credit calculations
  • Maximization of FDII

Our comprehensive international compliance services for businesses and individuals with international activities are in satisfaction of all U.S. filing obligations. International operations can generate a variety of different U.S. filing obligations, including (but certainly not limited to):

  • FinCEN Report 114, Report of Foreign Bank and Financial Accounts
  • Form 5471, Controlled Foreign Corporations
  • Form 5472, Foreign Owned Corporations
  • Form 8865, Controlled Foreign Partnerships
  • Form 8858, Foreign Disregarded Entities
  • Form 2555, Earned Income Exclusion for Individuals
  • Form 1116 and Form 1118, Foreign Tax Credits
  • Form 8804, Withholding on Partnership Allocations to Foreign Partners
  • Form W-8BEN, Foreign Persons Claim for Reduced Withholding Rates
  • Form 8833, Treaty Based Return Disclosures
  • Form 8832, Entity Classification Elections
  • And a variety of other international related forms that Katz, Sapper & Miller can prepare and provide related planning services

Katz, Sapper & Miller’s international resources also include our membership with PrimeGlobal, a global association of independent accounting firms. Through PrimeGlobal, independent member firms offer the strength and capabilities of a large, worldwide organization with technical depth and geographic reach impossible for a local firm alone.