Our team blends Big Four experience with agile execution. We establish a clear working framework—objectives, jurisdictions, milestones, and documentation—to reduce operational friction and deliver tax information that is accurate, comparable, and defensible in front of auditors, lenders, and tax authorities.
Business entity selection and legal structure
Analysis of alternatives (LLC, S corporation, C corporation, partnership, or branch) with projected tax and operational impact, coordinated with your legal advisors where needed.
International ownership structuring
Design of efficient ownership structures for cross-border investments and operations, taking into account treaties, compliance requirements, and tax efficiency.
Strategic international tax planning
Tax optimization for businesses and executives, maximizing credits, deductions, and incentives available in each jurisdiction.
Expansion due diligence
Tax and legal assessment of new markets, mergers, or acquisitions, with a focus on risks, opportunities, and compliance costs.
Inbound/outbound executive planning
Comprehensive advice for expatriates and mobile executives, ensuring full compliance while optimizing the use of treaties and available tax benefits for both the company and its executives.
Reporting and disclosure
Compliance with local and international regimes, including FATCA reporting, BEPS-related measures, FBAR reporting, and transparency / beneficial ownership rules.
Double tax treaty planning
Strategic application of double tax treaties to avoid double taxation and reduce withholding, supported by beneficial owner and LOB documentation (including W-8 series forms where relevant).
Passive Foreign Investment Companies (PFIC) analysis
Determining PFIC status, modeling tax implications, and designing strategies to manage or mitigate the burden in international portfolios of individuals and family offices.
Every global expansion brings its own mix of challenges: legal entity choices, transfer pricing rules, CFC/GILTI reporting, different tax regimes and legal obligations in new markets, tax treaties, and local disclosure and reporting. We begin with a comprehensive assessment of the group (entities, commercial and cash flows, jurisdictions, applicable treaties) and design a plan that combines strategy and compliance in a single, coherent framework.
Frequently Asked Questions
Which countries do you work with?
No. We operate from Florida and support companies with a presence across the U.S. and globally, with clients in the Americas and the Caribbean, Europe, Middle East and Africa.
Can you coordinate with local advisors or firms in other countries?
Yes. We work alongside local firms in each country to ensure on-time compliance, consistent filings, and alignment with your global tax strategy.
Is transfer pricing included in this service?
Yes. We prepare policies, intercompany agreements, and supporting files under the OECD Transfer Pricing Guidelines (Master File, Local File, and CbCR where required), coordinating with local advisors as needed.
What are the benefits of a global structural review?
Better alignment among subsidiaries, fewer unnecessary withholdings, fewer compliance surprises, greater transparency for third parties, and a stronger base for future expansions or transactions.
How often should we revisit our international structure?
Ideally once a year, or whenever there is a major change such as acquisitions, entry into new markets, new business lines, or significant tax reforms.
Efficient structure, reliable compliance, and frictionless expansion
We bring strategy, documentation, and compliance into a single workstream so your company can operate globally with confidence and agility. Schedule an initial 30-minute assessment and explore how to optimize your international tax structure without slowing your growth.
GUILLEN PUJOL CPA, P.A.
6161 Waterford District Dr., Suite 475 Miami, FL 33126
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GUILLEN PUJOL CPA, P.A.
6161 Waterford District Dr., Suite 475 Miami, FL 33126
GUILLEN PUJOL CPA, P.A.
6161 Waterford District Dr., Suite 475 Miami, FL 33126
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