Our Service to You

Mark L. Farber, CPA PC’s Financial Services practice has extensive experience providing tax and consulting services with a focus on investment partnerships, broker dealers, and international banks. Our clients range in size from start-ups to global financial institutions that require analysis of global tax strategies utilizing bank debt, securitization, commodities, derivatives and alternative investments including domestic and offshore transactions. Across these segments, Mark L. Farber brings an in-depth understanding of the complexities of your industry and the implications for your business. 

Mark L. Farber CPA PC’s Financial Services practice provides proactive guidance on existing and future accounting and tax regulations as well as other resources that provide value-added service to our clients. We’re committed to delivering the right solution with relevant industry experience to help you stay ahead of the many issues and challenges you face in a highly competitive industry.

Mark L. Farber CPA PC specializes in the taxation of U.S. branches and agencies of foreign banks. Branches are not regarded as distinct entities for most federal income tax purposes, rather, the United States taxes International Banks that are engaged in a trade or business within the United States on taxable income that is effectively connected with the conduct of that U.S. trade or business. As a result, there are numerous provisions in the Internal Revenue Code and the Treasury Regulations that significantly impact the tax liability of a U.S. branch or agency of an International Bank.

We have extensive experience with various provisions of the Code and Regulations that specifically impact the taxation of International Banks, including Treasury Regulation section 1.882-5, providing for the determination of the deductible interest expense of an International Bank attributable to its U.S. trade or business. We also consult and manage the compliance for the branch profits tax, and the branch level interest tax that effectively treats U.S. branches of International Banks as separate entities and the allocation of head office expenses to the United States trade or business. We also, understand the utilization of income tax treaties to provide tax benefits regarding attribution to a U.S. branch of business profits apply if it were a distinct and separate entity.

We retain significant experience in working with International Banks on the determination of a wide range of financial products to determine their effectively connected status. We have represented International Banks on the effectively connected issue before the Internal Revenue Service and numerous state tax authorities. We can also advise the Bank of the compliance issues that pertain to a transaction’s tax status as this issue not only affects the taxability of the transaction but also numerous tax information reporting requirements.