International Tax Attorney, NYC
Strategy And Succession For International Tax Matters From a New York City-Based Tax Attorney
In order to effectively handle an international tax issue, it is imperative to first have a thorough understanding of U.S. tax laws. At the law office of M. Bradford Randolph, Esq., PLLC, we understand the interplay of domestic and foreign taxation laws. For more than 25 years, attorney Randolph has been advising businesses and individuals with overseas and cross-border activities on how to best manage their global tax liabilities.
Who We Help
Located in Rockefeller Center in Manhattan, our firm provides international tax planning guidance to individuals and corporations worldwide. We help clients with overseas and cross-border activities navigate U.S. and international tax laws while addressing the tax, financial and business considerations associated with international operations.
Our international tax services can assist:
Individuals with foreign income, accounts and assets
Businesses operating internationally
Multinational corporations and their related entities
Businesses expanding into international markets
Companies involved in cross-border and intercompany transactions
Corporations evaluating international restructuring and tax planning opportunities
International tax matters can require compliance with the tax regulations of multiple countries simultaneously. Each country has its own rules, and understanding how to integrate business operations within this framework is critical to maintaining compliance and managing tax obligations.
Our experienced tax attorney can manage the legal side for you so that you can focus on business and financial operations. We work with clients to maintain compliance while structuring their businesses efficiently across different countries.
Offshore Voluntary Disclosure
International tax matters may involve foreign accounts, offshore assets and previously undisclosed foreign income. The allure of perceived tax havens can be tempting, but without a thorough knowledge of the legal implications, taxpayers can inadvertently breach regulations. This can lead to severe penalties and damage to one's financial and reputational standing.
One of the common challenges we help clients address is managing funds and assets in foreign accounts. We help individuals and businesses understand the U.S. tax and reporting considerations associated with offshore financial activity and evaluate appropriate options for addressing previously undisclosed foreign accounts or income.
Our services include helping individuals take advantage of the IRS Voluntary Disclosure Program where applicable. Because disclosure and compliance options depend on the particular facts and applicable rules, it is important to evaluate the circumstances carefully before taking action.
FBAR & FATCA Reporting And Enforcement
Foreign financial accounts and assets can create additional U.S. tax and reporting obligations. Businesses and individuals with overseas financial interests need to understand the requirements that may apply to their particular circumstances.
Our firm helps clients address international tax compliance issues involving foreign accounts and assets, including considerations associated with FBAR and FATCA reporting.
Properly managing foreign account information is an important part of international tax compliance. Mismanagement of overseas accounts can escalate into legal and tax issues if reporting requirements are not properly addressed.
We help clients understand the applicable reporting obligations and work through international tax issues involving foreign financial accounts and assets while considering the relevant U.S. and foreign requirements.
US Taxation Of Foreign Income
At M. Bradford Randolph, Esq., PLLC, we assist individuals and corporations with issues regarding U.S. taxation of foreign income.
U.S. taxation of foreign income can become complex when income is earned, received or allocated across multiple jurisdictions. Taxpayers may need to consider U.S. tax rules together with the tax laws of the countries in which they conduct business or hold investments and other assets.
International tax planning requires an understanding of how domestic and foreign taxation laws interact. Depending on the circumstances, foreign income may also involve foreign taxes, international business structures, related-party transactions and tax treaty considerations.
Our firm helps clients evaluate these issues as part of a broader international tax strategy, with the goal of appropriately managing worldwide tax liabilities while complying with applicable U.S. and foreign laws.
International Business Tax
International business tax management is a highly specialized skill, requiring a thorough understanding of both domestic and international tax law, accounting and finance.
Our services include:
International business tax management, including how to navigate intercompany pricing issues
Handling issues regarding U.S. taxation of foreign income
International corporate tax planning and restructuring
Transfer pricing and related-party transaction considerations
Managing the allocation of income, expenses and debt among related entities
International tax treaty considerations
Cross-border business and expansion planning
Helping businesses understand international tax compliance and reporting requirements
Helping businesses and individuals take advantage of applicable tax planning opportunities under the Tax Cuts and Jobs Act of 2017 (TCJA)
Corporate Tax Risk And Restructuring
The crux of international tax planning is minimizing global book and cash tax rates. At M. Bradford Randolph, Esq., PLLC, we know how to use international restructuring to lower both our clients' U.S. taxes and their worldwide income tax liabilities while taking applicable U.S. and foreign laws into account.
Organizations with international operations often benefit from corporate restructuring. Asset transfers and cost-sharing mechanisms allow worldwide corporations to share capital expenditures, debts and income and to diversify risk, often leading to lower global tax liabilities.
International tax practitioners walk a tight line. They must strike a fine balance between minimizing a corporation's global tax liabilities and following U.S. and foreign country legal requirements.
Attorney Randolph specializes in reducing a company's global tax liabilities in accordance with U.S. and foreign laws. He also has extensive experience in comparing and contrasting the treaty networks of various countries to optimize a company's worldwide corporate structure, thereby minimizing its global book and cash tax rates.
Transfer Pricing And Arm's-Length Transactions
Many corporations rely on accountants to determine the global allocation of income and expenses, usually referred to as intercompany pricing or IRC Section 482. It is important to consult with an experienced tax attorney who understands the legal implications of various allocation decisions.
The allocation of profits between a multinational corporation and its subsidiaries or sister corporations is not inherently improper when transactions are structured and priced in accordance with applicable arm's-length principles. An arm's-length approach generally considers what the price or terms would be if the transaction took place between independent companies under comparable circumstances.
Companies can run into problems when related-party transactions are not appropriately structured or supported, potentially leading to disputes, adjustments, double taxation or other tax consequences.
As an attorney and a CPA, Attorney Randolph can help clients cut through the complexities of international tax law to determine an appropriate transfer pricing method given the company's circumstances.
International Tax Compliance And Risk
The complexity of international tax law arises from the need to comply with the tax regulations of multiple countries simultaneously. Each country has its own set of rules, and understanding how to integrate business operations within this framework is critical to maintaining compliance and managing tax obligations.
We work with clients so that they maintain full compliance while structuring their businesses efficiently across different countries. Our goal is to help clients avoid the pitfalls of international finance, including the mismanagement of overseas accounts and improperly structured international transactions.
Country-By-Country Reporting & BEAT
International tax laws constantly change as the business community expands globally. Gaps between the tax codes of various countries create potential pitfalls for businesses seeking to operate internationally.
One such issue that has caught the attention of domestic and international tax authorities is base erosion and profit shifting, where a company transfers profits from one country to another to take advantage of lower corporate income tax rates. This can reduce the corporate income tax base of the jurisdiction in which economic activity occurs.
Profit shifting can be part of an international tax strategy, but businesses must carefully distinguish legitimate tax planning from arrangements that may create civil or criminal liability or other compliance concerns.
The U.S. government addressed aspects of this issue as part of the Tax Cuts and Jobs Act of 2017 (TCJA). Attorney Randolph can help businesses understand how applicable U.S. international tax rules affect their international operations and how those provisions fit into their broader corporate tax planning.
Country-By-Country Reporting
In its efforts to curb base erosion and profit shifting by multinational corporations, the Organisation for Economic Co-operation and Development (OECD) developed guidelines designed to increase transparency and global cooperation among international trading partners.
Country-by-country reporting is associated with the OECD's BEPS framework and can require qualifying multinational enterprises to provide information concerning their activities in the tax jurisdictions where they operate. Depending on the applicable rules and circumstances, this information can include revenue, profits before tax, income taxes paid and accrued, and other information concerning the multinational group's activities.
These international tax reporting requirements can create significant challenges for businesses operating internationally and those seeking to expand into international markets.
At M. Bradford Randolph, Esq., PLLC, we have more than 25 years of experience managing the progression of tax law as it applies to businesses operating in the U.S. and overseas. We are equipped to assist multinational businesses, or businesses seeking to expand their international presence, with preparations for applicable country-by-country reporting and related compliance requirements.
We can assist with:
The preparation or coordination of tax returns within the countries in which your business operates and, if applicable, the country-by-country template
Reconciling local tax returns with applicable country-by-country reporting information
Aligning internal reporting with applicable international reporting requirements
Anticipating the effect that international tax reporting requirements may have on a current business model and intended growth opportunities
Base Erosion And Anti-Abuse Tax (BEAT)
The Base Erosion and Anti-Abuse Tax (BEAT) was introduced as part of the Tax Cuts and Jobs Act of 2017 and addresses certain base-eroding payments and transactions involving foreign related parties.
Businesses with international operations may need to consider BEAT alongside transfer pricing, intercompany transactions, foreign income taxation and other U.S. international tax rules.
Attorney Randolph can help businesses understand how applicable provisions affect their international business and how international tax planning can be structured while taking U.S. and foreign legal requirements into account.
Minimizing Global Book And Cash Tax Rates
Corporate international tax management is a highly specialized skill, requiring a thorough understanding of both domestic and international tax law, accounting and finance. At the law office of M. Bradford Randolph, Esq., PLLC, we help corporations manage their global cash and book tax rates, while keeping them financially competitive in the marketplace.
Attorney Randolph can help your company to benefit from applicable tax law changes, including the Tax Cuts and Jobs Act of 2017 (TCJA), in evaluating strategies to manage book and cash tax rates.
Located in Rockefeller Center, in Manhattan, M. Bradford Randolph, Esq., PLLC, has been providing international tax and foreign income tax management services to international corporations for more than 25 years.
Allow Us To Manage Your Corporate Foreign Tax Issues
Balance sheets are not only indicative of a corporation's financial health, but they also reflect tax liabilities. At the law office of M. Bradford Randolph, Esq., PLLC, we use strategic allocation to optimize corporations' balance sheets and manage their book and cash tax rates.
Many corporations rely on accountants to determine the global allocation of income and expenses, usually referred to as intercompany pricing or IRC Section 482. It is important to consult with an experienced tax attorney who understands the legal implications of various allocation decisions.
Attorney Randolph combines legal and accounting experience when evaluating the allocation of expenses, debt and income. He understands the potential effect that international tax matters can have on a company's financial position and works closely with corporate officers to create corporate foreign tax management plans that take into account tax, financial and business considerations.
Legal And Financial Skills That Stand Apart
In addition to being an experienced tax lawyer, Attorney Randolph is a CPA and holds an MBA. Over the years, Mr. Randolph has held numerous tax and accounting positions in some of the world's most prestigious corporations. Attorney Randolph has both Big Law and Big Four accounting experience.
He understands the complexities involved in international tax planning. Corporations and individuals turn to Mr. Randolph for his sophisticated understanding of U.S. and international tax laws and the high-level counsel needed to effectively manage worldwide tax liabilities.
His combined legal, accounting and financial background allows him to consider international tax matters from multiple perspectives, including tax compliance, corporate structure, financial reporting and business objectives.
Manage Your International Risk. Call Us Today.
Many corporations have operations in foreign markets. It is important to have a well-laid exit strategy in the event government unrest threatens your financial safety and corporate goodwill. At M. Bradford Randolph, Esq., PLLC, we develop comprehensive international safety nets that allow foreign corporate operations to be quickly shut down and relocated in the event of an international threat. By creating these plans, we provide stability and peace of mind to corporations with international functions.
Schedule a consultation with an attorney online or by calling 212-759-0097.
For over 25 years, I’ve helped clients in New York and beyond with tax and business law matters. I’m committed to exceptional service and strong client relationships.
Our Services
CONTACT INFORMATION
Address: 45 Rockefeller Plaza FL 20, New York, NY 10111
Office hours :
Mon - Friday: 9:30 AM to 5:30 PM
except holidays
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