Navigating Unknown Territory: Top 10 International Considerations
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Entering the U.S. market or taking your U.S. business abroad adds a whole new set of complex laws, operating regulations and country-specific policies to the challenges of running a business. At Houston CPA and advisory firm Doeren Mayhew's 2014 client conference, international tax and advisory leaders Carrie Koshkin and Jennifer Mailhes shared best practices and real client experiences for steering clear of risks, managing tax implications and improving intra-company operations.
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Navigating Unknown Territory: Top 10 International Considerations
- 3. Consideration 1: Export Incentives • IC‐DISC: Export incentive – IC‐DISC is paid a commission by the related party – The related party receives a deduction for this commission payment – IC‐DISC is not taxed on the commission income – The IC‐DISC is deemed to make dividend distributions to its shareholders, which are taxed at the dividend rate Copyright © 2014.
- 4. Consideration 2: Taxable Presence • Statutory: U.S. trade or business • Income tax treaties: Permanent establishment Copyright © 2014.
- 5. Consideration 3: Business Form • Entity classification election • Deferral v. flow‐through structures Copyright © 2014.
- 6. Consideration 4: Foreign Tax Credits • U.S. provides a credit for foreign taxes – Limited to U.S. tax on foreign sourced income Copyright © 2014.
- 7. Consideration 5: U.S. Tax Filings • U.S. companies must file U.S. informational returns for the foreign entities they control • Foreign‐owned U.S. companies must file U.S. tax returns and informational returns – Foreign business with U.S. trade or business must also file Copyright © 2014.
- 8. Consideration 6: Leveraging Skill Sets General Manager Skill Set • All the skills of a CEO and more • Typically a GM is hired to grow U.S. or foreign sales, but they must have hand in all three areas of the business: CEO/GM Sales & Marketing Operations Administration Copyright © 2014.
- 9. Consideration 6: Leveraging Skill Sets Entrepreneurial • Decisions on allocation of resources ‐ money, people, effort • Communicating vision • Motivating team • Understanding all areas of the business Corporate • Understanding of culture and differences in practices • Knowing overall vision • Influencing direction so it can be embraced by the local team • Optimizing leverage between locations • Appropriateness of controls • Not full autonomy of business owner Copyright © 2014.
- 10. Consideration #7: Executing the Strategy Carrying Out the Vision • Understand why the parent company came to the United States or the other way around and articulate that to your team on the ground here • Make sure the local vision is compelling to attract, retain, motivate in that culture Copyright © 2014.
- 11. Consideration 8: Reporting Understanding What to Report Back • Key communications tool • Use to build successes and explain challenges Copyright © 2014.
- 12. Consideration 9: Rethinking What Works Understanding That Practices That Worked in Parent Country May Not Work Here • Competitive compensation • Appropriate benefits • Structure of local office to service clients Copyright © 2014.
- 13. Consideration 10: Communicating Maintaining Appropriate Dialogue Back & Forth • Understand company cultures in both offices • Use foreign resources where appropriate • Make sure you have appropriate authority in the local office to be successful and flexible Copyright © 2014.