Elisa M. Fay

Phone: +1 (404) 586-3594

Rödl National Tax (“RNT”) is the tax-technical core of Rödl & Partner USA. Drawing on significant public accounting and industry experience, RNT offers a distinctive breadth and depth of tax knowledge.

RNT’s Mission

To provide quality technical tax services to our clients. In support of this mission, we also monitor, analyze, and communicate relevant tax developments. 

RNT’s Commitments

 White glove service 

  • Timely responses 
  • Transparent, up-front scope and fee agreements
  • Technically accurate, practical recommendations

RNT’s Services 

RNT serves as a resource for high level tax expertise, specialized tax consulting, and comprehensive tax support. RNT also monitors tax developments and communicates timely, relevant information to you, our clients. 

We understand the unique challenges of entering the U.S. market and making cross-border investments. We can help you navigate the uncertainties of the international tax landscape to balance wise business decisions with global tax optimization. Very often in the tax world, the “right” answer depends on numerous factors. We will work with you to understand your business goals in order to integrate the best possible tax solution.

We continuously collaborate with our Rödl & Partner colleagues in Germany and around the world to arrive at comprehensive solutions for our clients. Many Rödl & Partner USA advisors speak German and hold dual U.S. and German tax certifications. Whether your business is concentrated in the U.S. market or spans multiple countries and languages, we have an extensive network of resources to assist with your specific needs.

RNT’s Services – Detail

I. Structuring

Whether this is your first venture into the U.S., you have been here for years, or you are planning an expansion abroad, we can help you determine the best way to operate that both fits your business model and optimizes your global tax posture.   Specifically, we can help you with:

  • Choice of entity
  • Formation or liquidation of a U.S. business
  • Existing business structure reorganization
  • Business acquisition and divesture strategy, analysis and support
  • Due diligence and deal support
  • Global tax optimization

II. Tax Controversy and Voluntary Disclosure

Often taxpayers discover they have inadvertently failed to consider all of their tax filings, or they become aware of an issue upon receipt of correspondence from a tax authority. This can be intimidating, especially to those who are unfamiliar with the U.S. taxing regime. We can guide you through the complexity and assist you in explaining and defending your position, or remedying your deficiencies. Specifically, we can assist with: 

  • IRS Offshore Voluntary Disclosure and Streamlined Voluntary Disclosure Programs for individuals
  • IRS voluntary disclosure for business taxpayers
  • State voluntary disclosure programs
  • Federal and state examinations, audits and disputes
  • Notices and appeals
  • Refund claims

III. International Tax Services

International tax encompasses a broad range of areas and presents unique challenges for those coming into the U.S. or going abroad. Clients often find themselves asking: “What activities subject me or my company to a country’s tax regime?”; “How does the tax treaty apply?”; “How do I avoid double taxation?” These examples illustrate the complexity of international tax issues that can arise when operating or living in multiple countries. We can provide in-depth analysis and recommendations regarding the following issues:

  • Permanent establishment
  • Application of treaty benefits including limitation on benefits 
  • Foreign Account Tax Compliance Act (“FATCA”)
  • Foreign withholding and related compliance including Forms W-8BEN-E, W-8BEN, and W-8IMY
  • Branch profits tax (“BPT”)
  • Foreign Investment in Real Property Tax Act (“FIRPTA”)
  • Passive Foreign Investment Company issues (“PFIC”) 
  • Foreign tax credit optimization
  • Fixed, determinable, annual or periodic (“FDAP”) income versus effectively connected income (“ECI”) and related allocations
  • Residency rules
  • Income sourcing
  • U.S. taxability of foreign earnings and related mandatory reporting, including controlled foreign corporations (“CFCs”) and Subpart F
  • Exit taxation
  • Cross border estate and gift tax planning
  • Succession planning
  • Wealth transfer tax strategies
  • Transfer Pricing

IV. U.S. Federal Tax Services

Nonresident investors with U.S. activities encounter unique issues in computing and reporting U.S. taxable income. Having tax advisors who are experienced with these issues reduces the risk of incurring substantial penalties down the road. We regularly advise clients on the following U.S. tax issues:

  • Effective tax asset utilization 
  • Complex partnership consulting including agreement review, income allocation, debt / equity analysis, among others
  • Accounting methods, periods and elections
  • Fixed asset analysis including tangible repair regulations
  • Affordable Care Act support
  • Interest deduction limitations
  • Distribution analysis
  • Like kind exchanges
  • Gain / loss analysis
  • Debt forgiveness
  • R&D and other credits and incentives
  • Return review

V. U.S. State and Local Tax Services

For those new to the U.S., and even for those who are experienced with the U.S. federal tax regime, the varying laws of our 50 states and thousands of local jurisdictions can be perplexing. Each state has its own laws and states generally do not follow tax treaties with other countries. So while U.S. federal taxation may not be a significant issue for your business, state and local taxation almost always is. We can help you navigate state and local tax issues, including: 

  • Nexus analysis and tax filing requirements
  • Sourcing of income
  • R&D and other credits and incentives
  • Sales tax troubleshooting
  • Sales tax outsourcing

RNT’s Expertise

Our team in Atlanta is made up of individuals with deep technical tax experience. We routinely advise on restructurings, voluntary disclosures, permanent establishments and nexus, treaty benefits, transfer pricing, and more. Most importantly, we understand that tax decisions must be approached from a practical perspective with a full appreciation of your unique circumstances and goals.  

Our RNT Services Team

The members of the RNT Services Team who will be primarily responsible for working with you are as follows:

  • Elisa Fay, Partner-In-Charge, CPA, over 25 years experience 
  • Bill Bradfield, Partner, CPA, over 35 years experience 
  • Ted Kresge, Of Counsel, CPA, over 40 years experience 
  • Dennis Wieckert, Of Counsel, CPA, over 40 years experience 
  • Lee Fritts, Associate Partner, CPA, over 25 years experience
  • Rachel Broniak, Manager, CPA, over 7 years experience 
  • Steve Ratmeyer, CPA, over 10 years experience