Over the years, A&A Management has assisted numerous businesses and their owners in starting and expanding their business operations. We know that success requires a team effort. Accountants, lawyers, bankers, insurance agents, technology consultants, and company personnel must work together to develop and implement a structure and systems that are appropriate to the needs of the business. Coordination of efforts is even more necessary when a business expands internationally, where legal, accounting, tax, and business conventions can differ dramatically.

We are committed to helping our clients achieve their goals, wherever those goals may lead them, and have assisted numerous clients in making the move across borders.

Our International Team is composed of both US and non-US natives with a wide range of tax and international experience.

Why A&A for International Tax?
We are committed to helping our clients achieve their goals, wherever those goals may lead them. In order to help clients make the move across borders, we provide the following services.

Multinational Business Structuring
The choice of how to structure your multinational business operations involves considering numerous factors. Nonbusiness factors, such as complexity or simplicity of operation, administrative costs, exit strategies, and tax minimization, are important contributors to the success of any business strategy. Whether you're a US company entering markets outside the US or a non-US business entering the US, A&A can assist you in developing the right business structure to meet your needs.

Employment Planning and Compliance
We can explore international assignment issues for your employees, including how they are compensated, who employs them, the assignment structure, and the application of tax treaties. We assist with the timely and accurate completion of US tax returns and tax equalizations for employees in different countries. We can help you avoid burdensome penalties for noncompliance with withholding rules, administer payrolls, prepare year-end documents, address benefit reporting issues, and review payroll, benefit, and expense systems to reduce exposure and enhance opportunities.

US Tax Withholding Compliance
As a general rule, payors of the US source income are required to withhold federal income tax from that income if they do not obtain certain documentation. Where the payee is a non-US resident, payors of US source income must obtain this documentation prior to making payments to the nonresident, even if the payor believes that the payee will not be subject to US tax on the payment because the income is exempted under the provisions of a treaty. In addition, partnerships engaged in business in the US must withhold on their foreign partners’ share of US source income, even if no distributions are made. These withholding requirements are often overlooked in conducting multi-nation transactions, and the penalties for failure to withhold can be onerous. A&A can analyze your withholding and documentation requirements to keep your business in compliance.

Transfer Pricing
The US and some foreign taxing authorities have adopted penalties for noncompliance with contemporaneous transfer pricing documentation rules. The IRS has increased examinations of small and mid-sized companies (under $1 billion in sales), believing there is weak taxpayer compliance and high tax penalty revenue opportunities. A&A can help protect you from these penalties.

Special Incentives for Exporters and Domestic Production
The US provides a host of incentives designed to foster US economic activity. Closely held exporters may benefit from the use of an interest-charged DISC. Many US producers may avail themselves of the new qualified production deduction. A&A can help you maximize your benefit from these US provisions to reduce your overall tax rate.

Multi-state Planning and Compliance
One of the biggest complexities facing businesses entering the US market is maneuvering the multitude of state and local taxes. A&A can help ease your entry into the US while minimizing taxes and administrative costs.

US Estate and Gift Planning
The US imposes taxes on the transfer of wealth in the form of estate, gift, and generation-skipping transfer taxes. These taxes can be particularly onerous for non-citizens who own US property. A&A can develop business and other structures to minimize the impact of these taxes for nonresident owners of US property. For individuals who are considering moving to the US, we can conduct pre-immigration planning to keep your pre-immigration assets out of the US transfer tax net.

A&A Management Outsourcing Services 

  • Internal audit services and functions
  • Section 404 compliance assistance
  • Accounting and controllership services
  • Multi-state tax planning and consulting
  • Expatriate tax services — compliance and consulting
  • International tax services — compliance and consulting
  • Executive income and estate planning
  • Human Resources — assistance in locating and hiring qualified financial personnel
  • Strategic planning and management meeting facilitation
  • General consulting services
  • Technology services — IT audit assistance and implementation
  • Monitoring asset-based lending programs for financial institutions
  • Preparing financial budgets and projections