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Almanza CPA Firm, LLC

Tax Advisory Services

Contact Us (210) 272-9793

Monthly Tax Advisory Services

Federal Compliance 

  • Tax accounting methods for recognition of income and deductions
  • Deduction substantiation requirements per IRC 6001
  • Compliance matters for foreign owned U.S. entities
  • Capitalization rules (funding with debt, equity, or both)
  • Related party transactions with domestic persons
  • Related party transactions with foreign persons 
  • Personal and real property depreciation methods and incentives
  • Tax Treaty implications - e.g. tie breaker rules, closer connection, LOB Transfer of Foreign Stock to US Entity
  • FTC & Participation Exemption
  • Anti-Deferral Provisions - Subpart F Rules
  • CFC Rules - downward and upward attribution
  • Sec. 367 – Outbound, Inbound, and Foreign-to-Foreign Transfers of Property 
  • GILTI, FDII, or flow-through structure 
  • Guidance to determine the amount of global intangible low-taxed income (GILTI) included in the gross income of certain U.S. shareholders of foreign corporations, including U.S.shareholders that are members of a consolidated group.
  • Guidance for the allowance of a deduction for the eligible percentage of Foreign-Derived Intangible Income (FDII)
  • Audit and representation in inspections by tax authorities

State and Local Compliance Considertions

  • State tax permits and registrations 
  • Analyze business operations to consult and comply with state regulations based on nexus for purposes of sales tax,franchise tax, personal property tax, excise taxes, and state income and/or franchise tax

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