Perspectives

Non-US investors use US Inbound International Tax and Transfer Pricing

Capturing value, keeping value

At Deloitte, we recognize that addressing foreign investment is a specialized area of tax. To focus on this important area we have created our US Inbound International Tax and Transfer Pricing Services group which practices within our worldwide tax practice network. It specifically addresses the issues that non-US investors face when they do business here, and includes more than 100 tax specialists around the world who focus on inbound tax planning.

How we can help

US Inbound International Tax and Transfer Pricing specialists can help you explore potentially tax-efficient structures for acquisition, financing, repatriation, and disposition. We can also help you understand current and planned changes to US tax laws and offer tax guidance during your investment life cycle. Furthermore, the group draws upon the knowledge of colleagues who are specialists in the various tax rules within their geographic locations. The result is that we offer our clients “home country” knowledge, “target country” knowledge, and industry experience through a single engagement.

​Inbound handbook

​More foreign direct investment flows into the United States than into any other country. There is more than $2 trillion in capital in the US that originated somewhere else–equal to about 16 percent of US gross domestic product. About 4.6 percent of privately employed people in the US work for American affiliates of overseas companies.
Having invested so much, non-US companies clearly intend to prosper and profit in the American marketplace. No organization plans to pay higher taxes. But surprisingly, few organizations plan as well as they could to address that expense.
 
Planning for multinational enterprises is subject to many external inputs–changing tax laws, treaty provisions, currency fluctuation, to name a few. These external influencers, along with ever-changing business performance, may limit predictability. It becomes harder to confirm that a multinational’s worldwide corporate tax burden and related cash flow challenges are being maintained at an acceptable level while helping to manage tax risks.
 
That’s why an organization’s tax planning should consider current and future investments in the US.

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