Andersen Tax

International Taxation

Much like the fast pace and rapid change of international business, Andersen Tax is a dynamic and nimble organization poised to meet your global tax needs.

We have extensive experience in advising new and mature multinational businesses. Our focus is on effective and efficient global tax planning that seamlessly integrates with your international business operations in a practical and proactive manner.

Our international tax professionals at Andersen Tax and the member firms and collaborating firms of Andersen Global help companies across a wide range of international expansion stages. Companies in the beginning stages of international expansion considering opening rep offices abroad, while not creating a permanent establishment, need particular attention and guidance. Andersen Tax specialized services for these early-stage companies include basic-to-sophisticated planning concerning: choice of an entity or a branch; acquisitions; joint ventures; financings; foreign-loss utilization, holding companies, IP planning and cost-sharing.

Later stage, more developed companies that manufacture and distribute outside the U.S. also have a unique set of needs. Andersen Tax professionals provide thorough, proactive solutions in complex tax matters that arise as companies grow from the early stages into the later, sophisticated stages of global expansion. Our approach to tax planning is driven by your business operations, not vice versa.

Some significant international tax practice areas that Andersen Tax provides include:


  • Foreign tax credit calculations including: income sourcing, expense apportionment, interest allocation, determining creditable foreign taxes and Sec. 78 gross-up
  • Dual consolidated loss determinations, calculations, elections and triggering-event exceptions
  • Foreign exchange planning and calculations
  • IRS and foreign tax filings
  • Elections and notifications
  • E&P and tax pool calculations
  • Earnings stripping planning, structuring and calculations
  • U.S. withholding tax determinations, remittance and compliance
  • CFC calculations and filings
  • PFIC calculations and filings

International and Domestic Tax Provision Calculations and Assistance

International Tax Consulting and Planning

  • International tax planning projections and calculations
  • Acquisition structuring and restructurings
  • Disposition planning
  • Cash repatriation
  • Subpart F minimization
  • Efficient use of foreign tax credits
  • Financings and re-financings
  • U.S. and foreign incentives
  • Tax treaty planning and interpretation including permanent establishment planning and determinations, limitation on benefits determinations and reducing or eliminating withholding taxes

Transfer Pricing

  • Contemporaneous documentation and penalty protection
  • Economic value chain / functional analysis
  • Benchmarking analysis
  • IRS and foreign audit support and defense
  • Planning including IP transfers, risk allocation, business operations re-structuring, among others.

U.S. and Foreign Tax Authorities Audit Defense and Support

U.S. and Foreign Tax Rulings and Opinions