Director, International Tax Services

+1 (866) 298-7829 Ext. 718 | todd.hedgpeth@wtpadvisors.com

Todd Hedgpeth, J.D., LL.M., is a Director of International Tax with nationally recognized boutique international tax consulting firm, WTP Advisors.

Todd brings over 21 years of international tax consulting, planning and compliance review experience to public and privately held businesses, high net-worth individuals and family offices. He has worked with clients across a variety of industries, including manufacturing, distribution and service, publicly traded technology firms, pharmaceutical and agricultural businesses, private equity firms, and hedge funds.

Certifications

• Licensed member of the Maryland State Bar Association

Education

• J.D. Mercer University School of Law
• LLM Tax Law, Boston University School of Law
• B.A. Political Science, West Virginia University

Professional Affiliations

• International Fiscal Association
• DFK International
• New York State Society of CPA’s

Areas of Interest/Expertise

• GILTI/Subpart F mitigation
• 965 Transition Tax Repatriation
• Private Equity Tax Structuring
• FDII Structures
• FTC Utilization
• M&A tax due diligence
• Post-Merger Integration
• IC-DISC optimization
• ASC-740 quantitative analysis
• Choice of entity (C Corp, LLC, S Corp, partnership, and foreign variations)
  • Financing analysis (Debt v. Equity)
• QC review of all international tax related forms and statements, including
  • Forms 5471, 8858, 8865, 1116, 1118, 926, 8938, 8992 and 8993, 8804, 8805, 8813, 1042, 1042-S, and 1042-T
  • Foreign bank account reporting
  • Section 332, 367 and 368 regulatory reporting requirements
• Consulting, QC review and/or preparation for OVDP submissions, Streamlined Offshore Compliance submissions and Delinquent International Information Return submissions
  • International Tax Controversy support and negotiation

• Inbound real estate investment consulting
  • FIRPTA mitigation and filing of Form 8288 and EIN/TIN applications
  • Foreign corporate blocker structures
  • Portfolio Interest Exemption loan structuring
  • Tax efficient ownership and exit strategies

• Pre-immigration planning
  • Asset protection strategies for foreign nationals immigrating to the U.S.
  • Tax shield strategies for both U.S. and foreign assets held in foreign trusts
  • Anti-deferral regime avoidance strategies
  • Basis step-up strategies
  • Tax residency analysis

• Trust & Estate planning
  • Structuring domestic and foreign trusts
  • Grantor and non-grantor trust analysis
  • Form 3520 and 3520-A review