US outbound corporate tax has become significantly more complex, especially as rules around Controlled Foreign Corporations (CFCs), Subpart F, GILTI/NCTI, foreign tax credits, and global minimum tax continue to evolve. Our goal is to help accounting firms extend their reach in this space, so you can confidently support globally expanding clients without needing to build a full in-house international tax team.
A dedicated US outbound tax partner for firms
At KNAV, there is a clear focus on US outbound corporate tax issues impacting CFC structures, foreign subsidiaries, and cross-border investments. This specialist focus complements your firm’s core services, enabling you to respond when clients ask outbound questions about foreign earnings, repatriation, or global expansion.
The support model is intentionally collaborative. KNAV works behind the scenes or alongside your team, depending on what fits best, so your client relationships remain central while you gain access to deep technical resources.
Advanced solutions for CFCs, GILTI/NCTI, and Subpart F
Rules governing CFCs and US shareholders have expanded in scope and complexity, including income inclusions under Subpart F and the net CFC tested income (formerly GILTI) regime. KNAV provides a comprehensive analysis of CFC ownership structures, entity classification, and earnings profiles, helping determine how these rules impact your clients.
Services include modeling net CFC-tested income, evaluating high-tax exclusions, assessing foreign tax credit availability, and coordinating interactions with other international provisions and global minimum tax frameworks. The objective is to identify planning opportunities, avoid double taxation, and align tax positions with business objectives.
Compliance, provision, and reporting support
Outbound structures bring significant compliance and reporting obligations—ranging from US corporate returns with detailed international forms to global data needed for tax provision and ASC 740 reporting. KNAV assists with return preparation and review, CFC and foreign information reporting, earnings and profits (E&P) analyses, and foreign tax credit computations related to outbound operations.
The team also supports the integration of outbound positions into quarterly and annual tax provisions, including current and deferred tax effects of CFC inclusions, repatriation strategies, and changing law. This ensures that international tax positions are accurately reflected in financial statements and withstand auditor scrutiny.
Planning for expansion, restructuring, and repatriation
As your clients expand into new markets or reorganize their global footprint, outbound tax considerations become critical to deal with economics and long-term flexibility. KNAV advises on holding structures, financing arrangements, IP migration, and supply‑chain alignment, taking into account CFC rules, foreign withholding taxes, treaty networks, and future exit scenarios.
In addition, KNAV assists with repatriation strategies, including dividends, loans, and liquidations, modeling the impact on US taxable income, foreign tax credits, and cash positions. This helps you guide clients toward tax-efficient ways of accessing foreign cash while managing risk and disclosure requirements.
How KNAV works with your firm
The service is designed specifically for accounting firms that may not have a dedicated outbound or international tax team but need to support clients with growing global operations. Engagement models are flexible:
- Project-based support for specific outbound issues, transactions, or reviews.
- Ongoing advisory to act as your “on‑call” US outbound tax resource.
- Co-sourced models where KNAV works with your internal tax specialists on recurring international work.
In every case, your firm remains at the center of the client relationship, while KNAV provides the technical depth and execution capacity needed to deliver high-quality advice.
Empowering your firm and your clients
Partnering with KNAV allows your firm to expand its service portfolio without the cost and lead time of building a full international tax bench. You gain access to a team that lives and breathes US outbound corporate tax, including CFCs, GILTI/NCTI, Subpart F, foreign tax credits, and emerging global minimum tax rules.
For your clients, this translates into proactive, technically sound guidance that keeps their international structures compliant, tax‑efficient, and aligned with evolving global rules. As their global footprint grows, your firm can grow alongside them—with KNAV as a trusted, behind-the-scenes partner delivering comprehensive US outbound tax services for accounting firms.
