TAXATION
We provide U.S. federal, international, and state tax services to smaller and mid-sized businesses. We prepare and file state and federal tax returns, perform research, prepare tax write-ups, address other compliance needs.
More specifically, our services include:
U.S. Federal Income Taxes
- Taxation of organizational and start-up cost;
- Qualifying, non-qualifying stock options and other equity-based awards;
- Property transfer transactions;
- Deductibility of interest cost under Sec. 163;
- Sec. 174 R&D expenses, including software development cost;
- R&D tax credits under Sec. 41
- Preparation of partnership tax returns, inside, outside basis adjustments;
- Preparation of corporate income tax returns for C and S corporations;
- Preparation of corporate income tax provisions, facilitating review by auditors;
- Preparation of ASC 740 disclosures, including income tax reconciliation;
- Deferred tax calculations, assessment of realizability of deferred tax assets;
International Taxation
- U.S. sourcing rules for dividends, interest, capital gains, personal services;
- U.S. income effectively connected to a U.S. trade or business;
- Taxation of controlled foreign corporations (CFC)- GILTI/NCTI regime, subpart F income
- Taxation of foreign income by U.S. domestic corporations- FDII/FDDEI
- Application of other Subchapter N provisions, including asset-use and business-activities tests;
- Taxation of partnership, including investment funds, with foreign partners;
- Chapter 3 withholding on FDAP income. other payments to foreign persons;
- Technical research and drafting memos;
State and local income & other taxes
- Evaluation of state tax nexus for income, sales, and use taxes;
- Multi-state apportionment and allocation of net income;
- Calculation of combined income for unitary groups under combined reporting rules;
- Analysis of state versus federal differences in NOLs, deductions, conformity issues;
- Preparation and filing of state income tax and sales/use tax returns;
- Assistance with property, franchise, and other state taxes;