With the tremendous expansion of world trade and investment in the past decade, multinational companies have elevated international tax planning to the top of their lists of issues they must effective address to return profits to their owners.  Due to the highly fragmented nationalistic tax systems, there are few general rules that are applicable across the board.  Instead, clients are forced to address the issues on a case-by-case, country-by-country basis.  Over the years, James Nobles LLC has gained considerable expertise in international taxation.  A few of the international tax services we provide to our clients are the following:

• Worldwide Tax Planning     For those multinationals who evaluate their worldwide tax burden with a view to reaching a targeted tax rate, we identify strategies to reduce the worldwide tax burden, and then assist the client in implementing the strategy.
  
  

• Foreign Tax Credit Planning     James Nobles LLC advises clients on planning for optimum use of the foreign tax credit under the complex U.S. rules which allow U.S. tax payers paying taxes to foreign countries to receive, under certain circumstances, a U.S. tax credit for the foreign taxes paid.
  
  

• Debt-Equity Planning and Compliance     Inbound foreign investors and outbound U.S. investors obtain a tax beneficial structure by optimizing the debt/equity ratios (or financial gearing) of their investments.  James Nobles LLC advises clients on compliance with debt/equity tax considerations so as to permit clients to obtain their investor's projected returns through the leveraging of the investment funds, while, at the same time, maintaining compliance with the lenders' requirements.
  
  

• IRS International Tax Controversies     The U.S. Internal Revenue Service has, in recent years, become more aggressive in auditing companies, both outbound U.S. investors as well as inbound foreign investors, for compliance with intercompany pricing and other rules.  James Nobles LLC provides representation to our clients in planning for these controversies as well as representing the clients before the IRS.
  
  

• Withholding Planning and Compliance     Companies and individuals making cross-border payments (for example, dividends, interest, royalty payments) are often required to withhold taxes and pay the withheld amounts over to the tax authorities.  If the appropriate amounts are not withheld, the payor will become liable for the tax.  James Nobles LLC advises clients on compliance with the withholding laws and the methods of compliance.