US Tax Group Deloitte Belgium

The Belgium-based team advises multinational businesses on U.S. income tax rules affecting inbound and outbound structures, helping clients manage their global effective tax rate while navigating increasingly complex U.S. tax rules.

• Advisory support for mergers, acquisitions, dispositions, restructuring, and financing.
• Treaty qualification, permanent establishment, withholding, and FATCA analysis.
• Foreign tax credit advice, Subpart F review, PFIC analysis, and transfer pricing-related considerations.
• Technical guidance on BEAT, GILTI, FDII, and broader U.S. tax reform implications.
• Preparation of U.S. tax filings, including federal, state, and partnership returns.
• Assistance with IRS audits, queries, and practical compliance execution.

Full range of US tax compliance obligations for corporate, partnership and state income tax filing obligations, international US tax filings,  assistance with quarterly estimated tax payments, tax treaty based tax returns and withholding obligations.

Pre-transaction planning

• Structuring and SPA review: Support on acquisition structuring, tax-specific deal issues, and alignment between diligence findings and deal execution.
• Target analysis: Review of tax attributes, legal entity considerations, and risk areas before entering or expanding in the U.S. market.

Due diligence execution

• Full-service tax diligence: Coverage across federal and state income tax, sales tax, property tax, transfer tax, treaty matters, and historical compliance issues.
• Tax factbook and issue tracking: Focused reporting to highlight exposures, opportunities, and areas requiring remediation before close.

Post-acquisition services

• Integration and compliance: Support with tax purchase price allocation filings, state registration, federal and state compliance, and post-deal governance.
• Improvement initiatives: Net operating loss analysis under IRC Section 382, tax basis studies, earnings and profits studies, entity rationalization, and state nexus review.

• ASC 740-10 advice and implementation support, including review of uncertain tax positions.
• IAS 12 procedures, deferred items calculation, and tax provision support under IFRS and U.S. GAAP.
• Quarterly and year-end close support for companies looking to streamline reporting.
• Tax provision audits, reviews, and centralized coordination of non-U.S. practitioners.
• Support with statutory financial statements preparation for non-U.S. entities.

• Tax accounting software implementation and process automation.
• Training, seminars, and technical updates on U.S. tax developments.
• Control implementation around the tax accounting process.
• Preparation of local teams for auditor and headquarters questions.

• European businesses entering the U.S. market.
• Groups acquired by a U.S. owner that need integration support.
• Organizations seeking more reliable U.S. tax compliance and reporting processes.
• Companies managing foreign tax credit, CFC, and treaty-driven planning issues.