schneider downs global services

international servicesAssurance, Tax and Business Advisory Assistance for Companies

Doing Business Around the World

Many companies are facing the challenges of prospering in the global marketplace. At Schneider Downs, our clients, both domestic and international, encounter these issues every day.

We routinely advise clients on all issues related to expanding into and operating within international markets. Schneider Downs helps our clients take full advantage of all of their international opportunities.

We provide a full suite of services to companies operating in multiple jurisdictions:

Accounting and Assurance Services• GAAPandStatutoryAudits• InternalAccountingandFinancialReportingServices• FinancialReporting• Start-UpCompanies

Internal Audit and Risk Advisory Services• InternalAuditCo-SourcingandOutsourcing• Sarbanes-OxleyCompliance• BusinessRiskAssessments• ITAudit• SSAE16/SOCReports

Tax Services• InternationalCorporateTaxServices• IndirectTaxes• Personal/ExpatriateTax• BusinessStructuring• TransferPricing

Business Advisory Services• BusinessProcessReengineering• DueDiligence• Valuations• TransactionAdvisoryServices

Corporate Finance• MergersandAcquisitions• EquityPlacements• CorporateDebtPlacements

Technology Advisors• SoftwareSolutions• ProjectManagement• BusinessIntelligence

Providing Services to International Companies SD GLOBAL SERVICES

SD Global Tax Services

SD Global Tax is a group of international taxspecialists providing domestic and international taxcomplianceandconsultingservices toU.S.and foreign companies operating in multiple jurisdictions.

Your company will benefit from SD Global TaxSD Global Tax professionals have extensiveexperience with the complex tax issues encountered by companies operating in international markets. Our strength lies in our abilitytorespondquicklytoclientinquiriesandprovide practical business recommendations based on thoughtful analysis of the tax issues and opportunities. We understand that many times all that is needed is a brief consultation to get you started in the right direction. Whether youneedaquickcalltogetyoustarted,orathoroughanalysisofyour current structure, we provide a wide array of international tax compliance and consulting services:

• Inbound and outbound entity structuring andcapitalization

• ReorganizationsforU.S.-ownedforeigncompanies• Foreigntaxcreditplanning• Cross-borderfinancingsolutions• Expatriateandinpatriateemployeetaxationissues• U.S.domesticandforeigntaxcompliance• Internationalwithholding taxesandapplicable treaty

provisions• Profitrepatriationandlossutilization• Transfer pricing assistance, including valuations and

economic analysis• Tax planning and implementation for Domestic

InternationalSalesCorporations• Managing tax aspects of intellectual property and

intangible assets

Examples of how SD Global Tax has served clients

• Permanent establishment and treaty issues – Provided a comprehensive analysis of company’s (and its employees) exposure to taxation throughout Europe,including an analysis of all applicable treaties.

• Domestic International Sales Corporation (DISC) – Structured and implemented a DISC for a consumerproducts manufacturer, resulting in tax savings of more than $1 million per year.

• Transfer pricing study – Completed a comprehensive transfer pricing study and documentation binder for

an international manufacturer with extensive intercompany transactions (products and services between worldwide subsidiaries).

• Expatriate Tax Services–Managedexpatriate program for multinational firm,including coordination with foreign payroll and income tax providers in seven countries.

• Outbound investment – Provided a comprehensiveanalysisofU.S.internationaland Japanese tax issues associated with the construction of a power plant in Japan.

• IRS and Canadian transfer pricing support– Provided transfer pricing economic analyses and documentation to support prices charged to foreign subsidiaryforbothU.S.andCanadianreporting.

•Cross-border financing–Reviewedalternativedebt/equitystructuresforU.S./Canadabusinessventuresand made recommendations to minimize worldwide income and withholding taxes.

• Foreign earnings repatriation – Reviewed foreignoperations and entity structure for an S-Corporation with numerous foreign subsidiaries and made recommendations on dividend strategies and “check-the-box” elections.

• International employee movement – Conducted a comprehensive review of employee taxation and payroll tax rules associated with temporary assignments between various foreign subsidiaries andtheU.S.

• Foreign acquisition–StructuredanacquisitionofanItalianretailer tominimizeseller’s taxesandobtaintax basis step-up for the U.S. acquirer (Italian taxassistanceprovidedbyMilanIGAFPolarisaffiliate).

• Outbound entity structuring – Developed appropriate entitystructureforU.S.S-Corporation’sinvestmentinIreland.

• Sale of foreign subsidiary – Advised on strategies to minimize overall U.S. and Canadian taxes inconnectionwiththesaleofU.S.corporateassetsandCanadian subsidiary.

Our strength lies in our ability to respond

quickly to client inquiries and provide

practical business recommendations.

About Schneider Downs

Our Focus is YouAs one of the 60-largest accounting and business advisory firms in the U.S., Schneider Downs can meet all your global needs with an integrated service team of specialists. We are committed to delivering innovative business solutions that result in breakthrough ideas, providing responsive service that is proactive and timely and adds value to your business and building a business partnership that is based on trust and personal relationships.

Schneider Downs’ global delivery service model incorporates the IGAF Polaris association of 384 independent accounting firms in 89 countries. Member firms have been selected as best in class for quality of practice, professional standing, size, local reputation, diverse technical capabilities and geographic location. Schneider Downs works with IGAF Polaris member firms throughout the world to coordinate our clients’ business needs.

© 2012 Schneider Downs & Co., Inc.

Cynthia J. Hoffman, CPA, J.D.International Tax DirectorTax Advisory [email protected]

Mark E. Cobetto, CPAShareholderTax Advisory [email protected]

Mary D. Richter, CPAShareholderTax Advisory [email protected]

David E. Kolan, CPAShareholderAssurance and Advisory [email protected]

SD GLOBAL LEADERSHIP

Daniel P. Phillips, CPAShareholderTax Advisory [email protected]

IGAF PolarisA Global Association of Independent Firms

1133 Penn AvenuePittsburgh, PA 15222(412) 261-3644

41 South High Street, Suite 2100Columbus, OH 43215(614) 621-4060

www.schneiderdowns.com