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On Demand
International Tax
Legal Knowledge
Challenge
Companies with overseas business and
those with foreign ownership must
comply with complex US tax reporting
rules or face stiff penalties.
How the Industry Solves It!
A few CPA firms have developed
excellent international resources, but
most firms are struggling to handle
the demands of international tax.
Why The Current Way Of Solving
This Challenge Fails
● Non specialists need more support to
deliver effective international tax advice.
The Impact If You Do Not Address It
● Clients get a less than optimum experience
● Some clients will leave for larger firms with a
deeper international bench
● Risk of bad advice for clients
● Potential fraud allegations for failure to inquire
into international assets and transactions
● Inefficient use of time in finding relevant
information
Value to You
● Have more time to spend on business
development
● Reduce project management costs
● Avoid risk and expense
● Increase customer satisfaction
3 Reasons We are The Best At It
1. Rapid response to legal tax questions and
issues in all stages of tax strategy and IRS
dispute resolution.
2. Predictive outcomes based on accurate
historical analysis and update to rules
3. Persuasive documents with context and a
logical framework.
About Us
On Demand Legal Services is the brand of tax attorney
Paul D. Wigg-Maxwell.
The name reflects his commitment to supporting
accountants with timely and practical international tax
and legal support based on his thirty-years of
experience.
Mr. Wigg-Maxwell received his JD from Columbia Law
School and his LLM from NYU Law School. Mr. Wigg-
Maxwell established his practice in 1994 after spending
1986 through 1994 in the tax department of a major
New York City law firm.
9
Real ROI Branding
Positioning and Messaging
Reason 1
Rapid response to legal tax questions and
issues in all stages of tax strategy and IRS
dispute resolution.
Why This is Important to You
• Avoid penalties
• Save time
• Eliminate the need to recruit and manage
multiple legal counselors.
Why us
● Knowledge of
● U.S. and international tax laws.
How We Do It
● Our lawyers access our knowledge base of
memorandums, research and outcomes
applying domestic and International Tax treaty
rulings to accelerate the research and
authoring of your response or memorandum.
Client: CPA Firm
Situation
The tax partner frequently required legal research to support their
strategy to address complex legal ax issues of high value clients.
Challenges
In order to complete the projects, the tax partner needed a response
in a timely manner.
Solution On Demand Legal Services provides rapid respond to legal research
and positioning memos.
Results
The Tax Partner saved time managing projects
Higher client satisfaction due to rapid resolution
Increased revenue with more free time to develop new business
Firm avoided costs of 1 FTE
Success Story 1
Reason 2
Persuasive documents with context
and a logical framework.
Why Reason 2 is Important
• Less consultation fees
• Avoid spending time responding to
tax official requests for clarification.
Why Us
• Each aspect of your case is explained in
• everyday business language
• Increasing the client’s ability to administer
compliance and
• Enhancing persuasiveness in tax
controversies.
How We Do It 2
We provide a logical framework and
provide context to support the position
and ensure it is easily understood.
Client: CPA Firm
Situation
Firm client is a professional athlete client who is not a U.S. citizen
and plays in a foreign league outside the U.S. He has family and a
home in the U.S. He overstays in U.S. and fails the substantial
presence test for the year. He faces U.S. tax on over $500k of foreign
income.
Challenges
Treaty is not available. Athlete is not a citizen of country where
league plays and is not tax as a resident in country where league
plays.
Solution
Our advice was to use the closer connection test under U.S. law. We
presented a detailed memo in support of this position relying on
facts and circumstances and analysis of precedent. The memo was
accepted without audit.
Results
Athlete saves over $125k by paying only 15% foreign tax on his
income rather than higher U.S. tax rate. The firm and client avoided an
audit and related additional expense.
Success Story 2
Reason 3
Predictive outcomes based on
accurate historical analysis and
update to rules.
3 Why This is Important to You
Avoid costs by reducing rework and
minimizing the steps in the tax
resolution process.
Why Us 3
● Strong transactional experience
● Varied country and culture knowledge
● Detailed Tax Treaty and International
Agreement experience
● Practical experience with compliance
● Competent authority experience
● Transfer pricing advice
How We Do It 3
● Our Legal Knowledge work-flows efficiently gather necessary
data.
● We rapidly identify relevant authority based on understanding of
the development of the field.
● Skill in weighing probable outcomes considering cost, benefits
and risks.
● Each aspect of your case is explained in everyday business
language increasing the client’s ability to administer compliance
and enhancing persuasiveness in tax controversies.
Success Story 3
Client: CPA Firm
Situation
Acquired a new client, who wanted advice on placing an employee in
UK to boost their sales.
Challenges Reducing UK Takes on sales initiated by employee
Solution
Restrict employee from entering into contracts binding on home
office thereby exempting all his leads from UK tax under US UK Tax
Treaty permanent establishment rules
Results
Net tax savings to client first year 25k.
Avoiding UK tax filings of 10k per year in professional fees
25
Grow your practice with on-demand legal knowledge who
can rapidly respond to design and defend the most tax
efficient tax strategies for each client.

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On Demand International Tax Services

  • 2. Challenge Companies with overseas business and those with foreign ownership must comply with complex US tax reporting rules or face stiff penalties.
  • 3. How the Industry Solves It! A few CPA firms have developed excellent international resources, but most firms are struggling to handle the demands of international tax.
  • 4. Why The Current Way Of Solving This Challenge Fails ● Non specialists need more support to deliver effective international tax advice.
  • 5. The Impact If You Do Not Address It ● Clients get a less than optimum experience ● Some clients will leave for larger firms with a deeper international bench ● Risk of bad advice for clients ● Potential fraud allegations for failure to inquire into international assets and transactions ● Inefficient use of time in finding relevant information
  • 6. Value to You ● Have more time to spend on business development ● Reduce project management costs ● Avoid risk and expense ● Increase customer satisfaction
  • 7. 3 Reasons We are The Best At It 1. Rapid response to legal tax questions and issues in all stages of tax strategy and IRS dispute resolution. 2. Predictive outcomes based on accurate historical analysis and update to rules 3. Persuasive documents with context and a logical framework.
  • 8. About Us On Demand Legal Services is the brand of tax attorney Paul D. Wigg-Maxwell. The name reflects his commitment to supporting accountants with timely and practical international tax and legal support based on his thirty-years of experience. Mr. Wigg-Maxwell received his JD from Columbia Law School and his LLM from NYU Law School. Mr. Wigg- Maxwell established his practice in 1994 after spending 1986 through 1994 in the tax department of a major New York City law firm.
  • 10. Reason 1 Rapid response to legal tax questions and issues in all stages of tax strategy and IRS dispute resolution.
  • 11. Why This is Important to You • Avoid penalties • Save time • Eliminate the need to recruit and manage multiple legal counselors.
  • 12. Why us ● Knowledge of ● U.S. and international tax laws.
  • 13. How We Do It ● Our lawyers access our knowledge base of memorandums, research and outcomes applying domestic and International Tax treaty rulings to accelerate the research and authoring of your response or memorandum.
  • 14. Client: CPA Firm Situation The tax partner frequently required legal research to support their strategy to address complex legal ax issues of high value clients. Challenges In order to complete the projects, the tax partner needed a response in a timely manner. Solution On Demand Legal Services provides rapid respond to legal research and positioning memos. Results The Tax Partner saved time managing projects Higher client satisfaction due to rapid resolution Increased revenue with more free time to develop new business Firm avoided costs of 1 FTE Success Story 1
  • 15. Reason 2 Persuasive documents with context and a logical framework.
  • 16. Why Reason 2 is Important • Less consultation fees • Avoid spending time responding to tax official requests for clarification.
  • 17. Why Us • Each aspect of your case is explained in • everyday business language • Increasing the client’s ability to administer compliance and • Enhancing persuasiveness in tax controversies.
  • 18. How We Do It 2 We provide a logical framework and provide context to support the position and ensure it is easily understood.
  • 19. Client: CPA Firm Situation Firm client is a professional athlete client who is not a U.S. citizen and plays in a foreign league outside the U.S. He has family and a home in the U.S. He overstays in U.S. and fails the substantial presence test for the year. He faces U.S. tax on over $500k of foreign income. Challenges Treaty is not available. Athlete is not a citizen of country where league plays and is not tax as a resident in country where league plays. Solution Our advice was to use the closer connection test under U.S. law. We presented a detailed memo in support of this position relying on facts and circumstances and analysis of precedent. The memo was accepted without audit. Results Athlete saves over $125k by paying only 15% foreign tax on his income rather than higher U.S. tax rate. The firm and client avoided an audit and related additional expense. Success Story 2
  • 20. Reason 3 Predictive outcomes based on accurate historical analysis and update to rules.
  • 21. 3 Why This is Important to You Avoid costs by reducing rework and minimizing the steps in the tax resolution process.
  • 22. Why Us 3 ● Strong transactional experience ● Varied country and culture knowledge ● Detailed Tax Treaty and International Agreement experience ● Practical experience with compliance ● Competent authority experience ● Transfer pricing advice
  • 23. How We Do It 3 ● Our Legal Knowledge work-flows efficiently gather necessary data. ● We rapidly identify relevant authority based on understanding of the development of the field. ● Skill in weighing probable outcomes considering cost, benefits and risks. ● Each aspect of your case is explained in everyday business language increasing the client’s ability to administer compliance and enhancing persuasiveness in tax controversies.
  • 24. Success Story 3 Client: CPA Firm Situation Acquired a new client, who wanted advice on placing an employee in UK to boost their sales. Challenges Reducing UK Takes on sales initiated by employee Solution Restrict employee from entering into contracts binding on home office thereby exempting all his leads from UK tax under US UK Tax Treaty permanent establishment rules Results Net tax savings to client first year 25k. Avoiding UK tax filings of 10k per year in professional fees
  • 25. 25 Grow your practice with on-demand legal knowledge who can rapidly respond to design and defend the most tax efficient tax strategies for each client.