Tax Structuring

Outbound Tax Structuring

InGame Enterprise professionals can work with you to understand the impact of changing tax laws on the income from your foreign operations. We will work with local firms to develop cross-border structures. These structures seek to minimize taxes assessed on your earnings stream and the return of those earnings to U.S. owners.

Our outbound tax structuring services consider:

• The local tax regime that applies to in-country operations
• Withholding taxes that apply to outbound payments
• Timing considerations in the United States

Our professionals also assist clients with income tax provision reporting these operations. We will also arrange transfer pricing services and foreign tax credit calculations.

Inbound Tax Structuring

We work with foreign businesses considering the U.S. as a location for their production, distribution, and other operations. InGame Enterprise professionals can assist in developing cross-border structures. These structures seek to minimize the taxes assessed on the earnings stream and their return to the foreign owners.

We can work with you to:

• Select the appropriate operating entity in the United States
• Select foreign intermediate holding companies
• Capitalize debt vs equity in your U.S. business
• Advise on the receipt of transfer pricing services and documentation
• Minimize withholding taxes
• Determine the applicability of treaty provisions

Tax Structuring of Disposal or Investment

Disposition transactions can range from outright sales, to mergers, to the formation of joint ventures. These transactions could involve multiple taxing jurisdictions including states, cities and foreign countries. The optimal tax structure can vary greatly due to the wide variety of factors at play.

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InGame Enterprise professionals can work with you to effectively prepare your business for transaction. This process can start years in advance, allowing us to organize operations and ownership for a tax-efficient transaction.

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As the transaction nears, we will work with the buyers, joint venture partners, and merger partners. We can assist in optimizing the tax results of transactions to the divesting parties. We will also seek to eliminate or defer the net tax costs where possible and consistent with the law.

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