International Tax Planning, Positioning & Defensibility

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For Complex Cross-Border Decisions.

CBOTaxAdvisors provides project-based international tax advisory focused on high-stakes cross-border situations where the cost of being wrong is significant. We work with clients who need clear planning, defensible tax positions, and formal documentation before making decisions that are difficult or impossible to reverse.

This is not tax preparation or routine compliance. Our work is designed to support judgment, planning, and downside protection.

What We Do

We advise on complex international tax issues where planning and documentation matter as much as outcomes, including:

• Cross-border entity and income structuring
  
• Transfer pricing and intercompany service arrangements
  
• Residency, relocation, and permanent establishment risk
  
• Exit tax and pre-exit positioning
  
• Ownership, control, and valuation-related tax issues
  
• Ambiguous or judgment-based tax positions

Our role is to identify risk, evaluate options, and clearly document the reasoning behind recommended approaches.

Defensible Planning & “Insurance-Grade” Documentation

A central part of our work is producing formal written memos that articulate:

• The relevant facts and assumptions
  
• Applicable tax frameworks and authorities
  
• Areas of uncertainty or judgment
  
• Risks accepted and alternatives rejected
  
• The rationale supporting the chosen position
  
• For many clients, these memos function as a form of practical insurance, as evidence of thoughtful, well-supported decision-making should a position later be reviewed, questioned, or audited.

How We Work

CBOTaxAdvisors operates on a clearly scoped, project-based advisory model. We do not provide:

• Bookkeeping or payroll
  
• Routine tax return preparation
  
• Ongoing compliance outsourcing
  
• Informal or off-the-cuff advice
  
• Each engagement is intentional, limited in scope, and concludes with a stand-alone written deliverable suitable for internal records, advisor coordination, or future reference.

Core Engagements

International Tax Decision Review

Fee: $5,000

A structured review of your current cross-border situation, focused on identifying:

• Material tax risks and exposure areas
  
• Structural or income attribution issues
  
• Transfer pricing or documentation gaps
  
• Viable paths forward
  
• Delivered as a Risk & Options Memo outlining what is defensible, what is fragile, and where further planning may be warranted.
  

Structure, Transfer Pricing & Positioning Blueprint

Fee: $10,000

For clients seeking to establish or refine a defensible structure.

May include:

• Entity and income architecture
  
• Intercompany services and transfer pricing considerations
  
• Valuation touchpoints and supportable ranges
  
• Tax position framing and documentation strategy
  
• Forward-looking trigger points for reevaluation
  
• Delivered as a formal planning memo with diagrams, assumptions, and risk commentary.

Exit, Relocation & Irreversible Decision Review

Fee: $15,000

For high-stakes situations such as:

• Exit tax exposure
  
• Major relocations or residency changes
  
• Asset or IP repositioning
  
• Ownership or control changes
  
• Includes scenario analysis, timing considerations, and a point-of-no-return framework, all documented in a comprehensive written memo.

Who We Work With

CBOTaxAdvisors is a good fit for clients who:

• Have international income, entities, or investments
  
• Are facing decisions that cannot easily be undone
  
• Value written analysis and defensible positions
  
• Prefer clarity and judgment over speed

Typical clients include globally mobile founders, consultants, investors, and individuals with cross-border operating or holding structures.

Who This Is Not For

CBOTaxAdvisors is not a fit for clients seeking:

• Tax preparation only
  
• Lowest-cost solutions
  
• One-off calls or informal opinions
  
• Ongoing operational accounting support

The practice is intentionally small and selective.

Advisory Profile

CBOTaxAdvisors is led by senior international tax professionals with extensive experience across:

• U.S. and cross-border tax planning
  
• Transfer pricing and income attribution
  
• Entity structuring and restructuring
  
• Valuation-related tax issues
  
• Formal tax position development
  
• High-stakes advisory and risk analysis

The practice emphasizes independence, depth of analysis, and defensibility over volume.

Getting Started

Engagements are limited and primarily referral-based.

If your situation involves a significant cross-border decision and you are seeking clear, documented analysis, you may inquire by email with a brief description of your circumstances.

All work begins with a clearly scoped proposal.

Contact:

info@cbotaxadvisors.com