Should you opt out of GILTI?
Explore the key tax reporting and planning considerations that can help determine whether the GILTI high-tax exclusion election is the right choice for your organization.
Capabilities built around your needs
Wipfli’s cross-border solutions can help guide organizations across industries toward international growth with practical guidance and relationship-focused support.
Global mobility services
Wipfli brings deep experience and a holistic approach to help organizations understand the individual and business tax implications of a global workforce. We look at the entire life cycle of an expat assignment, including support for shadow payroll, tax equalization calculations, hypothetical calculations, provision of tax counseling services and the preparation of an expat or inpat’s U.S. and non-U.S. individual tax returns.
Transfer pricing services
Wipfli offers cross-border planning and compliance support so that you can determine the appropriate arm’s length price for intercompany transactions under U.S. transfer pricing laws and regulations. Our team can also help you determine the arm’s length price according to OECD rules through our Allinial Global association.
We advise on specific transfer pricing issues unique to multinational enterprises and assist with U.S. and global transfer pricing documentation, intercompany agreements review and audit defense.
Global supply chain advisory services
Wipfli can assist with supply chain management strategy, helping create customized solutions that align with your goals by analyzing key supply chain levers. Our approach incorporates your internal expertise to develop practical, fully integrated strategies that optimize supply chain operations, including:
- Market analysis
- Manufacturing setup assistance and site selection
- Outsourcing 3PL selection
- Operation assessment, warehouse and inventory management
- Sales, distribution and customer support
- Integrated digital planning and technology within the supply chain system
Tariff solutions
Wipfli provides analysis to help your organization bridge IRS transfer pricing methods and requirements with U.S. customs transfer pricing valuation methods. With our bridge analysis, your organization can better determine the appropriate arm’s length price for intercompany sales acceptable to both the IRS and U.S. Customs and Border Protection.
We can also analyze options for unbundling (i.e., itemizing components of intercompany transactions such as goods, royalties and services) the dutiable value of goods. Our support can improve customs and IRS transfer pricing compliance by helping ensure that duties are not paid on non-dutiable elements. These services also support accurate functional segmentation and benchmarking.
Quantitative analysis
An increasingly global market makes it more critical than ever for your organization to understand cross-border taxation. Wipfli’s international tax team can support your organization with a range of services, including tax attribute analysis and tracking, calculating the impact of cross-border transactions or certain tax elections, cash repatriation and dispositions. We take our services beyond taxes, providing you with actionable guidance that aligns with your objectives and helps you clearly understand your next steps.
Wipfli takes a multidisciplinary approach to foreign direct investment advisory services, helping inbound companies aspiring to expand in the U.S. adopt a strategic plan and comprehensive roadmap.
Our services can support you in critical areas, including:
Wipfli applies a complex set of international tax rules to your factual situation to help determine your reporting requirements and how you can achieve tax-efficient transactions. Our experienced team also closely monitors developments and changes in tax law so that we can proactively advise you on the implications those developments may have on your specific situations as they arise.
State and local tax
Companies looking to expand in the U.S. need to navigate complicated state tax systems, as well as the direct and indirect taxes levied by localities such as counties or cities. Wipfli’s experienced state and local tax team can help you enhance your tax strategy and compliance with comprehensive support including state tax registration.
Payroll
Wipfli helps you comply with state and federal payroll regulations, including support for implementing a payroll system, reporting new hires, IRS Form 940 filing and making payroll tax deposits.
Outsourcing
Access enhanced oversight of your accounting function without the complexity or cost of building an in-house team. Wipfli offers comprehensive C-suite outsourcing, from accounting assistants and accounts payable clerks to controller and CFO positions. We take a customized, team-based approach to support business continuity and provide best practices tailored to your organization’s needs. We also offer outsourcing for CIO, COO, CHRO and vCISO positions.
Site selection
Wipfli can help you select the right site for your expansion, with support for data gathering, RFP distribution, bid review, and analysis and field visits.
Treasury management
Treasury management is critical for organizations with international sales and infrastructure. Our team can assist in reviewing all your treasury management functions across jurisdictions, including the U.S., and support good treasury management practices to help drive growth.
Technology
We offer comprehensive technology management for your U.S. operations, including support for designing and implementing the right tech infrastructure, managed services that can help protect and sustain your environment, and helpdesk support for your U.S.-based employees.
Our support for U.S. organizations looking to expand internationally includes:
International tax compliance and quantitative analysis
Wipfli’s international tax compliance team has deep knowledge of the complex U.S. tax filing requirements for taxpayers that have outbound operations and own foreign legal entities.
Our services include:
- Preparation of tax filing requirements in the U.S. (Form 5471, 8858s, etc.)
- Net CFC tested income (NCTI), foreign-derived deduction eligible income (FDDEI) and other tax attributes planning.
- Understanding IC-DISC tax incentives.
- Tax-efficient repatriation of foreign earnings.
We can also help you mitigate risks and penalties when delinquent international tax filings are uncovered.
Global compliance reporting and advisory services
Wipfli can help you navigate cross-border business environments while maintaining compliance with local tax, accounting and fiscal regulations. By leveraging global advisors within the Allinial Global association, Wipfli acts as a sole point of contact to clients for global coordination. This integrated model simplifies operations, consolidates billing and optimizes communication — driving both efficiency and effectiveness.
Our services include:
- Data collection
- Defining the scope of work for peer firms and communicating fee details
- Managing the tax calendar and sending reminders for upcoming statutory deadlines
- Providing regular updates to key stakeholders
- Monitoring fees and tracking progress on each deliverable
- Overseeing processes and resolving issues as they arise
EVENT | October 8, 2026
Nexus studies and voluntary disclosure agreements: How to manage multistate tax exposure
You could be exposed to state tax liabilities you don’t know about. State tax nexus can be triggered by a single remote employee, inventory stored in a third-party warehouse, or simply crossing an economic sales threshold. This webinar explores two of the most critical — and most frequently misunderstood — tools in multistate tax compliance: Nexus studies and voluntary disclosure agreements (VDAs).
EVENT | December 10, 2026
Year-end tax planning: Strategies, market outlook and opportunities
Is your tax strategy ready for year-end? Join us on December 10 for a webinar on how to proactively manage your tax position/liability instead of reacting after the fact. In this session, we’ll cover: • Proactive tax-planning strategies: Learn practical steps to strengthen your tax position now, including entity structure reviews, deduction planning and timing considerations. • Market signals heading into 2027: Hear how the current economic landscape may shape future financial and tax decisions. • Tax-savings opportunities: Discover anticipated tax incentives, credits and planning strategies you can take advantage of in the new year. Whether you want to reduce your tax burden, plan for growth or simply stay ahead of changing regulations, this webinar will equip you with actionable insights to end the year strong.
EVENT | December 16, 2026
Planning for 2027: What tariff, trade and policy shifts mean for manufacturers
Manufacturers are facing immediate challenges across their supply chains — from navigating tariff refunds and rising costs to managing supplier relationships and customer expectations. Many are also struggling to make decisions for 2027 and longer-term amid continued trade and policy uncertainty. Join Wipfli and the founder of Inside Beltway, a DC-based advisory and research firm, to learn what recent policy developments mean for manufacturers — and how to plan for whats next.
Reach out to our international expansion services team
Talk to our international advisors to learn how you can navigate global complexity and pursue growth with confidence.
