Newsroom

With locations around the world, there’s always something happening at WTP. Check this page often to view our latest announcements, press releases and appearances in the news.

Because WTP believes its clients and other businesses in need of tax services should be well informed of changes in tax and business law that might affect them, this section will also be updated with current information.

Press Release - WTP Advisors Expands Global Practice

International Tax Accounting and Compliance Services to Include UK

Media contacts: Ian Boccaccio, ian.boccaccio@wtpadvisors.com, 914.733.7733

or Carol Vieira, carol.vieira@wtpadvisors.com, 571.723.2432

July 14, 2010

White Plains, NY – WTP Advisors, a global tax and business advisory consultancy, announces an alliance with Hopkins Consulting, a UK-based tax and accounting firm. This partnership enables the award-winning WTP Advisors to offer tax and compliance services for both UK companies as well as multinationals with UK outfits.  

“WTP and Hopkins share similar expertise and philosophies. We have a wealth of ‘big four’ experience but prefer stronger relationships with our clients which in turn lead to tangible, valuable results for their companies,” says Ian Boccaccio, co-founder and principal of WTP Advisors.

And both WTP Advisors and Hopkins Consulting have a history of winning clients away from the big four because of their ability to respond on a dime, their efficiency, and their technical know-how.

However, while most of WTP Advisors’ existing clients have international operations, they tend to engage the big four for their tax compliance and accounting needs abroad.

“They do this for convenience, because the big four can provide global coverage,” explains Boccaccio, “however, we hear that some clients are dissatisfied with the cost and quality of the product they receive so we want to provide a WTP alternative to these clients for their international needs, much in the way we market an attractive alternative in the United States.”

In short, bringing a WTP branded UK firm to market for its clients will give WTP Advisors the foot-in-the-door it needs to compete for international business.  Hopkins has existing relationships with firms in Europe and in Ireland that WTP will seek to leverage.

“We are thrilled to be a part of WTP Advisors,” says Simon Hopkins, CEO and founder of Hopkins Consulting, “WTP’s expansion reflects its rapid success in this space, and supports the philosophy that people prefer a hands-on approach that emphasizes practical advice based on technical detail.”  Hopkins began the consultancy after working for more than a decade with Ernst & Young, one of the largest tax consultancies in the world. While there, he worked with major multinational corporations including Coca-Cola, Harley-Davidson, Times Mirror, GB Airways and DKNY.

Visit Hopkins Consulting online at http://www.hopkinsconsulting.co.uk

 


 

Press Release - The Changing Face of International Tax Planning

Consequences of Not Extending Favorable Subpart F Provisions

WTP Advisors

Media contacts: Ian Boccaccio, ian.boccaccio@wtpadvisors.com, 914.733.7733 or Carol Vieira, carol.vieira@wtpadvisors.com, 571.723.2432

June 2, 2010 

The Changing Face of International Tax Planning

New article examines consequences of not extending favorable subpart F provisions

White Plains, NY – As Congress decides the fate of key provisions affecting international tax planning that will impact thousands of U.S. multinational corporations and potentially turn previously deferred income into currently taxable income, a new article appearing in today’s issue of BNA’s Daily Tax Report from WTP Advisors’ Tax Director, Michael Lunardoni, offers valuable insight on preparing for the future of outbound international tax planning.

Currently, Congress is considering legislation that would extend two Subpart F exclusions (the Active Financing Exclusion and the Securities Dealer Exclusion) and a favorable Look-Through Rule, through the end of 2010.  These tax provisions are important to the competitive status of U.S. taxpayers engaged in financial services businesses abroad through controlled foreign corporations (“CFCs”). These provisions provide an exclusion from current taxation in the U.S. for dividends, interest and equivalent income earned abroad by financial services subsidiaries.  However, the future of these measures remains fuzzy. While the current Congress may extend these provisions through 2010, there’s no telling what the next Congress will decide.

“Many U.S. taxpayers engaged in financial services businesses abroad through subsidiaries rely on the Subpart F exclusions and the look-through rule; with their fates unclear, I wanted to provide information that would help taxpayers plan ahead in the event that these key provisions aren’t extended past 2010,” says Lunardoni.

The Active Financing Exclusion is the principal means by which taxpayers engaged in financial services businesses abroad, through CFCs, avoid having their income, including dividend, interest or equivalent income, currently taxed in the U.S. under the Subpart F provisions of the Internal Revenue Code.

The Securities Dealer Exclusion allows “regular dealers” in property who are also dealers in
securities under code section 475, to exclude from Subpart F income dividends, interest and equivalent income arising from transactions entered into in the ordinary course of the dealer’s trade or business.

The favorable Look-Through Rule refers to a Code section that excludes from Subpart F income certain dividends, interest, rents and royalties received from related CFCs, even when the payments are made across borders.

To this end, Lunardoni proposes that taxpayers prepare for the worst case scenario – that the provisions are not extended - and outlines the best next steps to take, including: 

  • Computing and reporting Subpart F income for CFCs that may have enjoyed a complete exemption from Subpart F income in prior years.
  • Claiming foreign tax credits or deductions for the foreign taxes associated with the deemed dividend income.
  • Updating and verifying the accuracy of the U.S. dollar tax pools and the functional currency earnings and profits pools that are needed to compute the foreign tax credits or deductions for each CFC reporting Subpart F income.  Taxpayers should assign a high priority to this task, since reconstituting these pools can be complex and time consuming.
  • Reviewing international structures that rely on the Look-Thru Rule to allow the cross-border circulation of earnings among groups of related CFCs.  Capital structure changes and transfers should be made while the Look-Thru Rule is in effect.
  • Revisiting dividend planning and cash utilization now that more CFC earnings will be subject to U.S. taxation under Subpart F.
  • Reexamining the calculation of deferred taxes related to equity (i.e., FAS 52 for Cumulative Translation Adjustments and FAS 133 for Other Comprehensive Income) to the extent a taxpayer’s structure contains entities whose earnings are no longer eligible for permanent reinvestment abroad under APB 23.

The full article can be found in the June 2, 2010 issue of Daily Tax Report. Mike Lunardoni can be reached directly at Michael.lunardoni@wtpadvisors.com or 914.733.7717.

About WTP Advisors

WTP Advisors is a leader in tax and business advisory services for a global marketplace. Our highly-skilled professionals equipped with years of industry experience, coupled with our cutting-edge technologies, make substantive and long-term differences to an organization’s
profitability. WTP Advisors is headquartered in White Plains, New York, with offices across North America, Asia and Europe.

To read the full article "What if the Extenders Stop Extending? The Consequences for Subpart F", click the Press Release link below.


Obama Tax Proposal Update

The Obama international tax proposals, which were announced in May 2009, have not been considered by the Congress as of January 2010. The president’s Economic Recovery Advisory Board, chaired by Paul Volcker, has yet to release its report on tax reform proposals, originally due in early December 2009. Recent articles in the press indicate that the original Obama tax proposals have been met with skepticism by the U.S. business community. Given the administration’s preoccupation with health care legislation and the importance of the November mid-term elections, the outlook for Congressional action on international tax proposals in 2010 is problematic, at best.


Obama International Tax Reform Proposals

On May 4, 2009, the Obama administration announced a sweeping tax reform proposal that would affect all US tax-payers doing business abroad and/or holding international investments.


Seven Small Jewels

Small firms are no longer flying under the radar. In these uncertain times, that much we can be sure of. In many ways, Consulting magazine’s Seven Small Jewels is a wonderful reflection of the profession itself, and this year’s winners represent the best small, niche firms of the profession. These “little firms that could” are having a big impact on the entire industry. In perhaps the most challenging economy the profession has ever witnessed, all seven of our Small Jewels managed to grow revenue in 2008, and all are projecting more growth for 2009. One firm even tripled its revenue last year and is anticipating another 75 percent growth for 2009. How’s that for a success story? And for many of the 2009 Seven Small Jewels, the economy may actually be helping: It’s leveling the playing field and affirming their leaner and more nimble business models.