Following the innovative game changers and global digital revolution of the last 20 years, tech companies around the world have unprecedented opportunities to reach new markets. The United States remains one of the most attractive markets for any tech company that wants to fuel their global growth, have access to investment capital and increase profits. The US is also a highly legalistic society with complex tax revenue codes and regulations that can be frustrating to translate into common knowledge, especially where there are grey areas in tax laws that have not evolved to address new technologies and how consumers around the world access products and services today.
The advancement of technology has created markets without borders and tech companies, in particular, have the ability to use cloud-based platforms and apps to transact and engage with people anywhere in the world. Companies can quickly and easily mass distribute products and online services, transacted with only the tap of a touch screen. Software as a service (SaaS), infrastructure as a service (IaaS) and platform as a service (PaaS) are some of the commonly offered cloud-based services. With cloud-based software platforms, the user usually does not have rights, possession or interest to the software. Instead, they pay to have access to the application itself or to products which can be downloaded and/or streamed from the platform. This poses a challenge in determining the character of income and whether a transaction results in the lease or provision of services.
We are proud to actively support the start-up community. Passionate entrepreneurs often look to the United States as a key place to fuel their next stage of growth.
We advise entrepreneurs on how to navigate the complex US tax landscape by gaining an understanding of their expansion goals – whether that starts as selling products and services to US customers, opening offices on the ground or obtaining US investment.
Considering the multi-state landscape of the US market, we develop a tax structure that will:
- Lower tax exposure to the parent company
- Minimize the group’s overall tax liability
- Determine US Effectively Connected Income and sources of income
- Assist with transfer pricing
- Assess state tax liability
- Analyze Permanent Establishment position
- Advise on cloud service implications
- Advise on locations & IP
- Provide reporting
- Advise on corporate structure
Our team of lawyers have extensive experience with tax treaties to ensure our clients gain double taxation relief.
We will help get your portfolio companies set up in the best way to support their dreams.
Our team mentors at tech events over the world. For help understanding your tax responsibilities from the start, contact Nora Rothrock.
Did you Know?
Fact SevenThanks to FATCA banks must disclose their American account holders to the IRS or local tax authority.
Fact SixThe IRS is actively looking for non compliant US persons.
Fact FiveIt takes an average of 16 hours to do IRS Form 1040.
Fact FourThere are over 500 IRS tax forms.
Fact ThreeSince 1916, illegal income has been taxable.
Fact TwoUS persons must file tax returns no matter where they live and work.
Text One7 million Americans abroad
only 500,000 compliant