Our International Tax professionals assist clients in minimizing worldwide tax burdens on business transactions and operations, understand international tax developments, and make effective foreign investments. Through our relationship with Baker Tilly International, Amper has unique access to a global network of world class firms. This enables you to take advantage of a full array of tax services for planning and implementing a comprehensive international tax strategy.

Corporate business leaders join forces with Amper's international tax professionals to creatively reduce taxes in the countries where they do business. Proven solutions include earnings repatriation, tax reduction and withholding tax minimization, cross border financing, investment planning, and general worldwide tax minimization strategies. Recognizing that tax and business alignment is critical to a company's success, companies engage Amper to proactively coordinate and execute their tax business strategy.

Mergers and Acquisitions
Constant change creates new and different company structures in an attempt to reduce cost and risk while increasing operational efficiency. Merging and restructuring to attain critical mass and strategic position can often achieve this.

Amper's tax specialists offer strategies and evaluate tax efficient structuring in such areas as cross border mergers, de-mergers, acquisitions, spin-offs, and joint venture agreements, as well as participate in the due diligence in today's environment of "deals."

Transfer Pricing
Transfer pricing is a term used to describe all aspects of inter-company pricing between or among related parties. The transfer pricing rules apply to both tangible and intangible property. Global integration and new business practices challenge multinational corporations to find innovative transfer pricing solutions. Stricter penalties (in both the U.S. and abroad), new documentation requirements, increased information exchange between countries, and improved tax auditor training and education are just some of the tools used by tax authorities to combat perceived abuses.

Our approach is not only to help your business comply with the transfer pricing documentation requirements, but also to help your business use the transfer pricing rules to its advantage.

Ask yourself the following:

• Is your worldwide effective tax rate out of line with statutory rates or industry standards?
• What are the key tax issues that face your business because of cross border transactions including transfer pricing issues?
• How should you structure foreign acquisitions, divestitures, or joint ventures to optimize your after tax cash flow?
• Have you considered the proper entity and jurisdiction to hold your intellectual property?
• Are you maximizing benefits through cash repatriation including dividends, interest and royalties?
• What VAT implications does your business face, if any?
• How do you obtain advance rulings on the use of royalties, finance arrangements, dividend flows, and treatment of specific instruments or activities?

The International Tax specialists at Amper are committed to helping businesses develop and implement the solutions that best meet their needs. Contact your client engagement partner, Rich Sackin at 732.287.1000.