Integrated Tax Planning for Your International EnterpriseThe global economy drives growth. But every market you enter means complex, new tax planning and compliance challenges – challenges that must be understood individually but addressed collectively. We offer the local knowledge and global perspective to deliver strategic, integrated tax solutions that help you capitalize on a world of opportunity. Our international tax practice’s deep experience in multinational structuring matters and advanced tax planning concerns includes outbound and inbound structure planning. foreign tax credits, worldwide tax minimization planning, transfer price analysis, ASC 740 (FAS 109/FIN 48), IFRS/GAAP convergence, foreign assignment planning and international business advice and planning. You can count on deep local resources around the world through our membership in RSM International. With 700 offices in more than 80 countries, RSM International delivers strong tax knowledge and capabilities to help build successful cross-border strategies that benefit your company and your stakeholders. Most Popular Insights  The application of the U.S. FATCA rules to international investment funds
Foreign investment funds face potentially burdensome withholding and reporting requirements under the new U.S. FATCA rules. While the application of these rules may change somewhat in forthcoming IRS guidance, it is very likely that the FATCA rules are here to stay.  New ITIN rules for 2012 tax filings may impose
new burdens The new IRS procedures for the Individual Taxpayer Identification Number (ITIN) application process impact taxpayers applying for an ITIN to use in preparing 2012 tax returns.  IRS encourages taxpayers to renew certain agreements before entering into a FATCA agreement
IRS indicates that qualified intermediaries should renew agreements on or before May 3 in order to be ready by date FATCA portal opens.  Brazil issues transfer pricing reporting requirement
New reporting rules require electronic reporting of all cross-border transactions related to the provision of services and the transfer of intangibles, and certain other transactions.  Argentina revokes tax treaty with Spain
The Argentine government's revocation of its tax treaty with Spain may significantly impact multinationals that relied on favorable provisions when structuring businesses in Latin America.  India – A transfer pricing overview
An overview of the Indian transfer pricing environment, key controversies regarding enforcement and suggestions on how companies can manage these challenges.  China initiates new VAT pilot program
China's new value added tax (VAT) pilot program may expand to replace the current business tax. This change could impact companies with transfer pricing agreements with Chinese subsidiaries.  IRS issues 2012 Offshore Voluntary Disclosure Program FAQs and guidance
The much anticipated frequently asked questions for the 2012 IRS Offshore Voluntary Disclosure Program were recently issued. It is important to note that the FAQs caution that the terms of the OVDP could change at any time, and the IRS could limit eligibility for the program or even end the program abruptly.  CPM - the World's Transfer Pricing Method
The transfer pricing comparable profits method (CPM) is the dominant method used by multinational companies today. Read about the adoption of the CPM in connection with recent legislative and regulatory changes. Additional Resources International Network Newsletter Podcasts |