When a client's business operates across multiple jurisdictions, the need to coordinate tax events and minimize the overall tax burden of the holding in all jurisdictions arises. This process is referred to as tax planning. The goals are accomplished through a combination of contractual tools, transfer pricing strategies, corporate and trust structures, as well as intellectual property management. Jurisdictions for these instruments are chosen based on whether double taxation treaties established and are categorized as “conduit jurisdictions” and “sink jurisdictions.”
The primary aim of tax planning is to ensure that the holding's profits are allocated to a jurisdiction with the lowest tax burden — the sink jurisdiction. This jurisdiction can serve either for long-term profit storage or as a "wallet jurisdiction" from which the business owner can draw funds for personal use.
In cases where the business involves multiple partners, tax planning facilitates the structuring of operations to prioritize the interests of specific partners during internal corporate disagreements.
My practices
Base erosion and profit shifting from the U.S.
Reporting foreign income of U.S. persons to IRS
Disputing Tax Deficiency before the IRS
Offshore tax solutions for U.S. taxpayers
Base erosion and profit shifting to offshore
Certain multinational enterprises may engage in cross-border tax optimization strategies, whereby taxable income is strategically reattributed to jurisdictions with more advantageous fiscal regimes. These strategies, commonly referred to as base erosion and profit shifting (BEPS), can involve the artificial manipulation of transfer pricing mechanisms or the utilization of deductible intercompany transactions, such as royalty or interest payments, to artificially shift profits to low- or no-tax jurisdictions. Consequently, the taxable base of higher-tax jurisdictions may be diminished, potentially impacting revenue generation and raising concerns regarding fairness and equity within the global tax landscape.
Tax strategies for international tax planning
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Reporting foreign income of U.S. persons to IRS
As an experienced professional specializing in international and U.S. taxation, I am here to guide you through the intricate realm of reporting foreign income to the Internal Revenue Service (IRS). My expertise enables individuals and businesses engaged in cross-border activities to effectively navigate complexities and reduce their tax obligations.
Through my comprehensive range of services, I provide you with a strategic roadmap tailored to address diverse challenges, including: double taxation relief, foreign tax credit, foreign earned income exclusion, Subpart F tax regime, global intangible low-taxed income (GILTI), passive foreign investment company (PFIC) structuring, controlled foreign corporation (CFC) structuring, base erosion and anti-abuse tax (BEAT), foreign account tax compliance act (FATCA) and report of foreign bank and financial accounts (FBAR), transfer pricing, disclosure of corporate control in foreign entities, tax residency planning and relocation, capital expatriation and repatriation,
Offshore tax solutions
I assist my clients in creating offshore entities, both in conduit and sink jurisdictions, tailor-made to their unique needs and risk tolerance. Whether you seek robust, long-term tax optimization or a temporary haven for your assets, I provide the strategic guidance and meticulous execution to navigate this intricate landscape with confidence.
Conduit jurisdictions are used to shift income from high-tax countries like U.S. to offshore sink jurisdictions where the profits are eventually stored. Conduit jurisdictions, boasting robust legal frameworks and transparency, facilitate legitimate tax planning through holding companies, intellectual property structures, and other BEPS tools. These solutions ensure compliance, mitigate risks, and pave the way for long-term financial stability. Conduit jurisdictions have extensive network of tax treaties with other developed countries like the U.S. and E.U. countries. Also, in general, conduit jurisdictions are used to make assets expatriation legitimate for tax authorities and political establishment of your country.
Sink jurisdictions, with their low or no tax burdens, can serve as both temporary and permanent destinations for capital seeking refuge from high-tax environments. They may offer immediate tax relief, surprisingly predictable political climate and clear legal framework. These qualities make them attractive options for certain wealth management strategies. My expertise lies in guiding you through this complex terrain, ensuring you leverage sink jurisdictions during the careful transfer of wealth to safer, compliant harbors.
Remember, optimizing your global tax position is not a one-size-fits-all endeavor. Contact me today for a confidential consultation and embark on a journey towards financial success, armed with the tools and expertise to navigate the ever-evolving world of international tax strategy.
Disputing tax deficiency before the IRS
If you are facing tax debt issues with the IRS, it is important to address them without delay. Unresolved tax obligations can negatively impact your immigration history and credit rating, and may lead to denials of U.S. citizenship or professional licenses.
I am ready to assist you at every stage of the process—from analyzing your tax situation to preparing the necessary documents and representing your interests before the IRS. My experience includes handling various tax issues, including those related to foreign income. Contact me to discuss how I can help you avoid negative consequences and find the optimal solution for your situation.
Sink jurisdictions
Cayman Islands
Panama
British Virgin Islands
These jurisdictions are used for the long-term keeping wealth that has been moved out of high-tax jurisdictions through third countries. Sink jurisdictions have high standards of information confidentiality, developed legal systems, and no agreements with third countries on cooperation in the field of criminal prosecution.
Viacheslav Kutuzov | International & U.S. Taxation Expert
We minimize your taxes domestically and internationally...
Viacheslav S. Kutuzov
VIACHESLAV S. KUTUZOV
International and U.S. Taxation Expert, admitted to practice before the IRS (No.00144810-EA)
55 Broadway, 4th floor, New York, New York 10006
We apply international standards of confidentiality
ISO / IEC 27001 Information security management
