International Tax

Global Withholding Tax Services

The Ryan International Tax team delivers substantial tax savings and refund opportunities through our Global Withholding Tax Review. In the European Union alone, an estimated € 5.47b of withholding tax relief goes unclaimed annually, according to the European Commission. A large percentage of that loss is attributable to cross-border tax leakage for the following reasons:

• Application of incorrect withholding tax rates or statutory law to cross-border payments (e.g., where a non-tax person holds responsibility for the withholding function)
• Non-claimed treaty benefits
• Non-claimed tax credits
• Noncompliance with local source country obligations

Ryan’s highly experienced global tax specialists employ proven methodologies to identify and reclaim any withholding tax that has been overpaid, utilizing a solution that is unique to the industry. Our analysis is comprehensive, covering third party and intercompany transactions, as well as the associated credits and withholding taxes. Ryan’s state-of-the-art technology, coupled with our service process, provides an enhanced, highly detailed, end-to-end global review, so our clients’ profits stay where they belong.

International Attribute Calculations

For Ryan’s International Tax team, the calculation of International Tax Attributes drives significant value to our clients’ U.S. tax posture; it is NOT a compliance exercise or a training ground. These calculations can include:

• Earnings and Profits (E&P) analyses
• Foreign tax pools
• Basis in non-U.S. stocks or assets
• Currency-related analyses (e.g., Sections 987, 988, etc.)

Many clients and other service providers take shortcuts with these calculations because they are difficult and data intensive, potentially covering multiple decades of a foreign entity’s existence. We relish difficult and data-intensive calculations; those provide the greatest opportunities to bring efficiency, improve calculation methods and accuracy, and most importantly, improve our clients’ results. Having performed thousands of calculations for the largest U.S. multinational companies, our work often produces benefits such as:

• Increased foreign tax credit utilization
• Audit-ready documentation of deemed paid foreign tax credits
• Reduced Subpart F inclusions
• Reduced effective tax rates for financial statement purposes

International ASC 740 Tax Accounting Services

With growing complexity in tax law, tax departments are under pressure to provide cost-effective, efficient processes that are accessible, visible, transparent, and adhere to regulatory controls. Ryan’s International Tax team has improved the global reporting process at the world’s largest corporations. Our professionals are highly experienced in tax reporting under ASC 740 (FAS 109) across a wide spectrum of industries, with services including:

• Analysis and calculation
• Tax rate/effective tax rate (ETR) analysis
• Tax account analysis
• Process automation for tax accounting
• Tax process improvement
• Controls
• Intercompany account analysis
• Provision software implementation

International Tax Compliance Services

The International Tax Compliance specialists at Ryan know that all of the following are true:

• Compliance is time consuming
• Compliance is difficult
• Compliance burdens are growing more onerous
• Tax authorities are more closely scrutinizing the compliance that has been filed

But the most important characteristic of compliance is the one that gets our greatest focus:

• Good compliance drives good value into the tax organization

When compliance is viewed as a commodity, the end product is only as good as what the lowest cost provider can produce. Good compliance pays for itself many times over. It becomes a strategic practice that can be comfortably used for planning and structural decisions. It reduces time spent “looking for numbers,” and it reduces time spent by external auditors and tax examiners. Good compliance contains good data that can be easily mined for innovative solutions that reduce tax burdens.

For this reason, Ryan’s International Tax team does not view compliance as a sideline or a training ground. With nearly three fourths of our staff at the position of Principal, Director, or Manager, we view compliance as a critical service offering for our clients—one to which we will allocate the strongest, most technical members of our team to ensure we drive good value into every tax organization we serve.

International Tax Structuring Services

In a challenging international tax landscape, Ryan provides multinational corporations with proven international tax structuring solutions and best practices for improving the profitability of mergers, acquisitions, supply chains, Enterprise Resource Planning (ERP) implementations, and more. Our service delivery methodology involves Ryan’s most senior International Tax professionals in the engagement from start to finish, bringing their years of experience working with global corporations to successfully develop and implement custom tax planning solutions that are unique to each client's business objectives. 

Our international tax structuring services include:

• Strategic tax planning and compliance
• Mergers and acquisitions (M&A) structuring (pre- and post-transaction)
• Global structuring solutions
• Intellectual property (IP) planning
• Supply chain strategies

Our internal resources include professionals dedicated to implementing our structuring solutions, and experts in compliance, provision, and reporting are an integral part of the International Tax team. We offer the most innovative International Tax solutions in the marketplace by coupling a comprehensive approach to tax planning with a pricing model customized to the success generated from our services.

Transfer Pricing Services

Ryan provides a comprehensive suite of transfer pricing services to proactively and efficiently manage the ever-changing global legislative and regulatory requirements and the growing potential for audit assessments. Our professionals address the business impact of cross-border transactions, as well as provide effective solutions that improve client profitability and reduce overall global tax liabilities by optimizing intercompany pricing from an operational and multinational tax perspective.

We understand our clients’ objectives and leverage our technical expertise in global transfer pricing principles to identify the proper balance in pricing cross-border transactions. Our ability to complement this expertise with our strategic approach and thorough understanding of international and value-added taxes ensures the highest level of value and delivery of client results. Our transfer pricing services include:

• Transfer pricing compliance
• Transfer pricing risk assessment
• Support in advance pricing agreements (APAs) and mutual agreement procedures (MAPs)
• Dispute resolution support

U.S. International Inbound Services

With one of the highest tax burdens in the world, the U.S. tax system requires sophisticated navigation to ensure taxes are not needlessly overpaid. Sophisticated navigation comes only through experience. Ryan’s International Tax team has industry-leading experience, whether the investment is the acquisition of an ongoing business, expansion of a global business into the U.S., or a simple acquisition of U.S. real estate.

Our U.S. inbound tax professionals provide timely and wide-ranging U.S. tax consulting advice to global companies and individuals, handling every aspect from “day one.” We respond quickly and bring our tax professionals from different tax disciplines to work closely together to leverage our accumulated knowledge and experience.

For many non-U.S. multinational companies, we work closely with their U.S. tax department, advising and assisting as needed; for some, we function as their U.S. tax department, handling all aspects of the tax organization. In either case, we align ourselves closely with the organization to ensure that the tax function is not just going through the motions but rather is exploring every available opportunity to minimize the tax burden of U.S. operations.

U.S. Production Incentive Services

Ryan’s seasoned International Tax team has extensive experience in creating recurring, permanent tax savings for businesses that manufacture, produce, grow, or extract in the U.S. through the utilization of Interest Charge Domestic International Sales Corporations (IC-DISCs) and other strategies.

Ryan employs in-depth knowledge of the complex areas of the applicable tax law, as well as powerful software tools, to maximize the tax savings available under the IC-DISC rules. We handle all aspects of forming and managing the IC-DISC, from incorporation through annual calculations and filings. At all times, our focus is on ensuring that our clients derive the highest applicable benefit for their activities.

Our international production incentive services include:

• Creating repeatable processes to effectively manage data gathering on an ongoing basis and establishing processes for recordkeeping and Internal Revenue Service (IRS) mandated documentation
• Identifying qualifying revenue streams
• Analyzing impact on other tax areas (e.g., state and local)
• Analyzing allocation and apportionment methodologies
• Analyzing multi-dimensional profitability, which is useful in business reviews
• Calculating transactional taxable income and reconciling tax-return data and financial information
• Developing transparent work paper trails
• Creating supportable documentation of qualified domestic production activity to withstand IRS scrutiny

VAT/GST Consulting Services

Rapid globalization, increased global trade, and expanded distribution and production channels create significant international growth challenges for multinational corporations. Managing VAT liabilities across a range of countries presents considerable financial risk, especially when the complexity of VAT is underestimated.

Ryan’s team of international VAT consulting professionals includes the industry’s most respected tax experts across North America, Europe, and Asia-Pacific. Our expertise in VAT recovery, compliance, and global deployment of tax automation solutions helps ensure our international clients are protected from overstated tax liabilities, interest charges, and costly penalties.

Visit the following Ryan international sites for additional information:

• Canada
• Europe
• Asia-Pacific

GILTI, FDII, and BEAT Optimization

Ryan brings extensive experience across industries in driving GILTI, FDII, and BEAT optimization while minimizing risk for multinational organizations.

Ryan offers extensive experience in consulting on global intangible low-taxed income (GILTI), a tax provision that requires U.S. shareholders to include foreign earnings as part of their U.S. taxable income. Our holistic approach includes a strategic review to minimize or exclude income subject to GILTI.

We also advise clients on foreign-derived intangible income (FDII), a tax incentive available to C corporations. Our proactive approach includes a strategic review of all business operations to identify sources of income that qualify for the incentive. Additionally, Ryan optimizes all elements of the calculation to enhance the qualified business asset investment (QBAI), deduction-eligible income (DEI), and foreign-derived deduction-eligible income (FDDEI).

The base erosion and anti-abuse tax (BEAT), which is applicable to certain corporate taxpayers, is essentially a minimum tax that is triggered when certain foreign payments are made, including deductible payments and depreciation benefits, or as a result in a reduction of the taxpayer’s gross receipts. Generally, the BEAT rate is 5% for tax year 2018 and periodically increases until 2026, when it reaches a rate of 12.5%. Ryan has dedicated expertise in evaluating all related party payments to minimize the impact of BEAT.