Expert advice for US tax issues: dual qualification and customized service from Frankfurt
Our experienced staff in Frankfurt have dual qualifications as German tax advisors and US Enrolled Agents. This unique expertise enables us to offer you comprehensive advice without the time difference. Our team is available in either German or English to ensure that your tax concerns are dealt with efficiently and accurately. Rely on our expertise to resolve your US tax issues and achieve the best possible results for you.
Our US Tax Desk advisors have the following areas of expertise:
Global Mobility
- Preparation of coordinated US and German income tax returns from a single source
- Preparation of US federal, state and local tax returns
- Correspondence with the tax authorities at federal and state level
- Filing of appeals
- Advice on assignments to the USA or from the USA to Germany
- Personal advice to employees in an individual meeting before the start and after the end of cross-border activities (so-called exit/arrival meetings)
- Advice on the tax consequences of business trips to the USA
- Individual tax optimization
- Cost estimates (e.g. calculation, allocation and deductibility of assignment costs)
- In-house training (e.g. on the tax consequences of business trips to the USA)
Private Clients
- Assistance with disclosure and taxation of income in the context of the US tax amnesty programs (Streamlined Foreign Offshore Procedures)
- Advice on inheritance and gift tax issues and preparation of necessary German and US tax returns (Forms 706 and 709)
- Advice on the correct taxation of interests held in foreign (non-US) partnerships and corporations. This includes in particular
- Preparation of the "check-the-box" election
- Classification as a "Controlled Foreign Corporation" (CFC) or "Controlled Foreign Partnership" (CFP)
- Classification as a "Passive Foreign Investment Company" (PFIC Testing)
- Preparation of forms for the reduction of US withholding tax at source (Form series W-8/W-9)
- Preparation of applications for reimbursement of US withholding tax
- Coordinated US and German tax advice on the structuring of US investments
- Advice on US exit tax (when giving up US citizenship or a green card; Form 8854)
Financial Services
- Support in the establishment of processes relating to US tax forms, in particular the W-9/W-8 series forms.
- Preparation of customized review instructions and plausibility checks for the W-9 / W-8 series forms.
- Support with onboarding processes for US tax forms and FATCA/CRS self-certifications.
- Review of treaty eligibility under a relevant double tax treaty ("DTA") with the US, taking into account the specific barriers (limitation on benefits) to treaty benefits and the investor base.
- Support in establishing and implementing processes to determine the 90% treaty threshold under the DTA Germany-USA for German investment funds.
- Classification of legal entities and products under the Foreign Account Tax Compliance Act ("FATCA") and the Common Reporting Standard ("CRS").
- Coordination with regard to the corresponding obligations and the resulting (due diligence) processes relating to FATCA and CRS.
- Advice on reporting under FATCA and CRS.
- Review of the historical, existing and planned investment portfolio with regard to effectively connected income from US sources and the associated tax filing obligations in the USA.
- Review of the historical and existing investment portfolio with regard to under- and over-withholding on US-relevant income.
- Advice on and preparation of specific US tax Reportings for US investors, e.g. for
- Passive Foreign Investment Companies ("PFICs") under the Qualified Electing Fund ("QEF") election to optimize US taxation of invested US persons.
- Reconciliation of German income statements to US tax law for high net worth US persons.
- Advice on and preparation of mandatory US tax returns based on effectively connected income from US sources.
- Advice on and preparation of mandatory US tax returns based on an underwithholding of tax on US investment income.
- Advice on and preparation of voluntary US tax returns based on an overwithholding of tax on US investment income.
