Financial Services companies, especially those having international operations or non-U.S. customers or shareholders, typically have unique tax requirements and planning opportunities. WTAS professionals with specialized Financial Services experience are available to help clients:

• Calculate taxable income — original issue discount and bond premium and market discount — from pools of prepayable debt obligations using the prepayment assumption catch-up (PAC) method
• Analyze and model consequences of dealer status under IRC Sec. 475 and mark-to-market elections for traders in securities and commodities
• Calculate Subpart F income from financial transactions
• Quantify income subject to gross-basis withholding (IRC Secs. 1441, 1442 and 1446) and help withholding agents comply with U.S. information-reporting rules
• Analyze and compute correct amount of income treated as effectively connected with a U.S. trade or business, including impact of special interest-allocation rules applicable to international banks
• Analyze and compute correct amount of income treated as effectively connected with a U.S. trade or business, including impact of special interest-allocation rules applicable to international banks
• Analyze structured finance transactions, including cross-border sale repurchase and securities lending arrangements, cross-border financings, securitizations and hybrid structures
• Analyze state/local tax consequences of structured finance transactions