Global Reach

The opportunities and risks in tax and regulatory compliance, mergers and acquisitions, the raising of investment capital are daunting enough when dealt domestically. When extended across borders into multiple jurisdictions, the problems and challenges increase exponentially. A vast majority of KNAV’s clients have international presence or ambitions and we have the expertise they need to help successfully manage complex, time-sensitive issues in a dynamic global environment.

We advise our clients on international tax structuring opportunities, transfer pricing, and due diligence matters. We also help our clients align their business objectives with their tax structure & comply with the ever-changing requirements of managing a business presence in foreign jurisdictions.

HOW WE MAINTAIN A GLOBAL PRESENCE

Member of Allinial Global   

KNAV is a member firm of Allinial Global, a network of independent accounting and consulting firms, which provides clients with additional worldwide access to a wealth of integrated resources.

Allinial Global is more than 220 members strong and growing, with locations throughout the world generating over $ 4.11 billion in collective revenues and was recently ranked the second largest accounting association in the world by The International Accounting Bulletin.

Due to their technical excellence, many Allinial Global members have been appointed to prestigious committees and boards such AICPA’s Technical Issues Committees, Employee Benefit Plans Expert Panel, Forensics and Valuation Services Executive Committee, and numerous State Boards of Accountancy.

There’s not a single question that cannot be answered within the Allinial Global membership because our collective experience offers both depth and breadth

www.allinialglobal.com

Member of IR Global

KNAV is a member of IR Global Network, a multi-disciplinary professional services network that provides legal, accountancy and financial advice in 155 + jurisdictions worldwide.

The membership consists of the highest quality boutique and mid-sized firms who service the mid-market. Firms are focused on partner led, personal service and have extensive cross border experience. They offer the highest quality advice, meeting the needs of the most complex client requirements.

Today the network exists as the ‘go-to’ network for forward-thinking clients looking for creative, pragmatic and cost-effective solutions.

www.irglobal.com

Member of Pride Partners International™ (PPI™)

KNAV is a member of Pride Partners International™ (PPI™), a global association of transfer pricing and financial valuation consulting firms with a presence in most entrepreneurial markets around the globe. Today, the global challenges regarding transfer pricing have become an inflexion point between worldwide tax compliance and the financial objectives of Multinational Enterprises (MNE). Members of this network have a clear understanding of these contemporary issues and work together to assess these new challenges. The network was born as an imminent response to global market needs, which demand a platform for international transfer pricing and valuation advisors that guarantees companies an efficient and professional service. Members of the network have a clear understanding of these contemporary issues and work together to assess these new challenges.

Joint Venture Partners in EUROPE

Our Partner in the Netherlands

With knowledge of Dutch GAAP, IFRS, IndAS, UK FRS and US GAAP, our team provides on-site accounting advice in the UK and Europe and, remotely, assistance in preparing the group’s consolidated financial statements.

Our team is highly adept at implementing complex accounting standards, including business combinations, revenue recognition, leasing, share-based fees, complex financial instruments and hedging transactions and income tax.

www.hlg.com

Our Partner in the UK

Our clients are both UK fast growing businesses seeking to increase efficiency of their finance function, as well as global inbound businesses setting up in the UK.

INTERNATIONAL FOCUS

  • Setting up in the UK (inbound)
  • Expanding overseas (outbound)
  • India Desk
  • French desk

www.aventuspartners.co.uk

INTERNATIONAL SERVICES

KNAV’s International Services Group is committed to providing quality tax, accounting, auditing and consulting services to private and public companies with global operations.

Areas of expertise

ESTATE AND GIFT TAX OF NON-RESIDENTS

Estate and Gift Tax Planning is a complicated endeavor in a domestic environment, but in a world of intensified globalization the transfer of wealth requires even more careful planning. International Transfer Tax Regimes in Common and Civil countries (Europe) are vastly different and require a deep understanding of the relevant concepts, such as the usufruct or German (Nießbrauch), French (Usufruit), Italian (Usufrutto), forced heirship, or the impact of a trust. Our estate and gift tax planning team helps you to avoid any pitfalls to preserve your assets and comply with the various rules and regulations.

  • Estate and gift tax planning for U.S. individuals and families with foreign assets
  • Advising non-resident persons with assets in the U.S.
  • Advising on U.S. information reporting on foreign assets, bank accounts, or gifts by foreign persons
  • Tax planning for wealth transfer in in-and outbound situations
  • Tax Treaty analysis
  • Expatriation tax planning and compliance
  • Preparation of estate – and gift tax returns

EXPATS/INPATS TAX SERVICES

With a more globally competitive world, staying informed about multi-faceted tax laws and managing the reputational risk that global employers face is essential. You need to ensure that you and your employees are aware of, and comply with, local compliance requirements.

Whether you have an inbound or outbound need, because you are entering a new market or expanding in a current one, KNAV can assist you.

TRANSFER PRICING

There are no “standard” transfer pricing or valuation approaches at KNAV because every business is different. Our experts deliver uniquely tailored insights to ensure your business gets exactly what it needs to move forward with confidence.

Our primary focus is always on helping you to increase tax efficiency while minimizing risk.

Our transfer pricing team offers services around:

  • Compliance and documentation
  • Strategy and planning
  • Audit defense

AUDIT INSIGHTS AND TECHNICAL GUIDANCE

More than 100 countries have adopted International Financial Reporting Standards (IFRS), either as issued by the International Accounting Standards Board (IASB) or as endorsed by a particular jurisdiction.

As your company proceeds through the transition to IFRS or converts to or from U.S. GAAP and IFRS, we can assist in making changes efficiently.

  • IFRS Transition
  • Conversion guidance IFRS to GAAP and GAAP to IFRS

 

INTERNATIONAL TAX

 

INTERNATIONAL TAX PLANNING FOR BUSINESS AND CORPORATE TRANSACTIONS

Our ties to the Asia-Pacific, European, and North American regions, and our extensive professional experience, make our tax experts the perfect partners for planning inbound and outbound acquisitions and transactions.

  • Tax Treaties and International Governmental Agreements—Whether your company is foreign-owned or a domestic corporation doing business in foreign nations, it is crucial to understand the impact of tax treaties on domestic law.
  • Cross Border Mergers and Acquisitions—Corporations must be aware of the importance of advanced tax planning when negotiating a merger or acquisition. Our experienced international M&A team helps you manage the risk and solve problems during the entire M&A process. Our services include:
    • Tax due diligence including federal, state and local tax, sales & use tax, payroll taxes and more;
    • Consulting on optimal structuring for acquisitions or dispositions in a global environment;
    • Advising on deductibility of various transaction costs in interplay with the foreign jurisdiction’s rules;
    • Analyzing restrictions on post-acquisition utilization of net operating loss and other tax attributes;
    • Analyzing available elections related to acquisition (such as 338 elections) to determine the most tax efficient manner of structuring an acquisition or disposition;
    • Advising on optimum acquisition vehicle & funding.
  • Outbound Investments
    • GILTI, FDII, Subpart F—These tax programs impact the bottom line of a U.S. corporation’s international prospects. We make sure that the international expansion of your company is well-structured and avoids any pitfalls.
    • Repatriation Planning—Setting up the right repatriation structure from the outset can help to avoid tax headaches down the road.
    • Reporting Requirements—Failure to adequately report foreign business can result in serious penalties.
  • Inbound Investments –
    • Choosing the right business entity—Certain business entities work better from a tax perspective with other entities in different jurisdictions. Depending on the entity type, and the way an entity is recognized in different jurisdictions, tax treatment will vary. LLCs, C Corporations, S Corporations, and disregarded entities each entail unique tax benefits and consequences.
    • S. Permanent Establishment (PE) risk—The risks of establishing a taxable presence in the U.S. or abroad parameters may lead to used to unforeseen tax implications;
    • Branch profits tax;
    • Withholding taxes ;
    • Tax treaty application and analysis—Foreign corporations interested in investing in the U.S. may qualify for tax savings under international governmental agreements and tax treaties;
    • Transfer Pricing.
  • Exit Strategy—Whether partners or shareholders are interested in moving on to new ventures, or a business is considering exiting a market, it is important to consider the financial and tax liabilities such changes may entail.

 

TAX PLANNING FOR INTERNATIONAL REAL ESTATE TRANSACTIONS

The U.S. real estate market offers several key advantages that keep international investors interested: stability, opportunity, and a strong record of growth. In addition, beneficial tax treatment draws the attention of European investors who want to take advantage of the lower tax rates in the U.S. while exempting themselves from taxation in their home country. These opportunities depend on the unique circumstances of the home country’s domestic law and tax treaties with the U.S. When considering such investment, it is imperative to:

  • Have a thorough knowledge of the Foreign Investment in Real Property Tax Act (FIRPTA) provisions to avoid any missteps;
  • Structure the investment with cross-border issues in mind—in particular, how the home country and the U.S. differ in their consideration of different entities, such as LLCs and S Corporations;
  • Understand the interplay between domestic and international provisions concerning capital gains, depreciation, the tax basis of acquired property, and passive losses and credits; and
  • Properly evaluate real estate transactions and assets according to the appropriate valuation principles. KNAV’s real estate valuation team is well versed in both the appropriate U.S. valuation principles and the U.S. real estate market.

 

TAX PLANNING, AUDITS, AND COMPLIANCE FOR AMERICAN EXPATRIATES AND BUSINESSES

As more businesses expand into global markets, more U.S. individuals find themselves working and conducting business overseas. U.S. taxpayers living abroad and American expatriates have unique and complex tax concerns both domestically and internationally. Individuals and businesses newly operating abroad may be overwhelmed by the procedures and obligations they find themselves faced with. Consulting with KNAV’s tax experts can help such individuals and businesses to plan for the tax implications of a life abroad.

 

FATCA AND FBAR COMPLIANCE

Many U.S. taxpayers may be surprised to learn that they are required to report their foreign asset holdings to the IRS. Those with U.S. citizenship are subject to the filing and reporting requirements of the U.S. whether they live in the U.S. or abroad, or even if they have never lived in the U.S. (accidental Americans).

Failure to comply with the U.S. filing requirements of either FATCA or FBAR on a timely and accurate basis can lead to penalties, fees, and criminal prosecution. The severity and the type of punishment for failing to file depends on the delinquent form, the magnitude of foreign asset or financial account holdings, and the willful intent (or lack thereof) which led to the incident.

It is not uncommon for taxpayers to be unaware of these obligations, or to misunderstand them. For taxpayers who find themselves out of compliance with the law, KNAV’s tax experts can help to address the failure and to mitigate the consequences entailed. We have experience guiding clients through the following programs designed to bring taxpayers back into compliance:

  1. Delinquent Submission Procedures—For clients who need to file delinquent forms, but have not misrepresented their foreign-source income.
  2. Streamlined Filing Compliance Procedures—For clients who need to file delinquent forms, and have non-willfully misrepresented their foreign-source income.
  3. Voluntary Disclosure Program—For clients who need to file delinquent forms, and have willfully misrepresented their foreign-source income.

The aggressive stance of the IRS and the hefty penalties involved with a failure to file means that it is generally preferable to cooperate and earn good-faith treatment. It is critical, however, to consult with a tax professional before coming into compliance with the IRS in cases where serious financial penalties or criminal prosecution are possible.

MEET OUR EXPERTS

Simone Alting

Associate Partner – US Tax and Advisory

simone.alting@knavcpa.com

Nishta Sharma

Managing Partner

nishta.sharma@knavcpa.com

Atul Deshmukh

Partner – International Assurance & Accounting Advisory

atul.deshmukh@knavcpa.com