Gray International (“Gray”) is an international network of public accounting and consulting firms based in the U.S., Hong Kong, China and Europe. Gray was started over 10 years ago in the U.S. (via its predecessor) and took the form of Gray International in 2013 as the result of the networking of multiple independent practices and professionals. Gray provides international accounting and compliance solutions in the U.S., Americas, Asia and Europe. Gray focuses on U.S. accounting, tax, and governmental compliance for multinational companies, investors, U.S. persons living overseas and foreign investors and companies investing in or moving to the U.S. Gray also consults on compliance with U.S. laws for businesses and financial institutions overseas such as the Foreign Corrupt Practices Act (FCPA) and the Foreign Account Tax Compliance Act (FATCA), the IRS Offshore Voluntary Disclosure Program, and the Program for Non-Prosecution Agreements or Non-Target letters for Swiss Banks. Gray’s principals, partners, and employees have served clients worldwide. Gray has offices in Geneva, Hong Kong, Seattle, Shanghai and plans to open an office in Singapore in late 2013. Gray’s U.S. public accounting firm (Gray CPA, PC) is registered with the U.S. Public Company Accounting Oversight Board and is a member of the American Institute of Certified Public Accountants and the Center for Audit Quality. For more information about us, please visit us at: www.grayintl.com

1. FIRM CREDENTIAL
Overview of services and qualifications
International
Accounting &
Compliance
GENEVA
|
HONG
KONG
|
SEATTLE
|
SHANGHAI

2. LEGAL NOTICE
IMPORTANT LEGAL INFORMATION PLEASE READ
This
presentation
is
prepared
for
general
guidance
only,
and
does
not
constitute
the
provision
of
accounting,
legal
or
tax
advice
in
any
manner,
written
tax
advice
under
U.S.
Internal
Revenue
Service
Circular
230,
or
any
professional
advice
of
any
kind.
“Gray
International”
or
“Gray”
refers
to
Gray
CPA,
PC
(a
U.S.
CertiIied
Public
Accounting
Iirm)
and
Gray
International
Ltd
(a
Hong
Kong
Limited
Company).
The
information
provided
in
this
presentation
should
not
be
a
substitute
for
consultation
with
qualiIied
professionals
who
understand
your
situation,
as
it
will
differ
from
others.
In
addition,
when
making
any
tax
planning
decisions
you
should
consult
with
your
own
legal,
tax,
accounting
and
other
professional
advisors.
This
presentation
has
been
provided
as
a
courtesy,
and
therefore
while
care
has
been
executed
in
the
preparation
of
this
information
Gray
CPA,
PC
(U.S.),
Gray
International,
Ltd.
and
all
of
their
afIiliates
make
no
representations
as
to
its
completeness,
accuracy
or
the
timeliness
of
the
information
and
takes
no
responsibility
to
update
this
information,
such
information
is
being
provided
without
warranty
of
any
kind.
©
2013
Gray
CPA,
PC
and
Gray
International
Ltd.
with
all
rights
reserved,
this
document
shall
not
be
reproduced
or
distributed
without
the
express
written
permission
of
Gray
CPA,
PC
or
Gray
International,
Ltd.
For
more
information
about
us,
please
visit
us
at
www.grayintl.com.
International
Accounting &
Compliance

3. WHO WE ARE
OUR
PROFILE
Gray
International
(“Gray”)
is
an
international
network
of
public
accounting
and
consulting
Iirms
based
in
the
U.S.,
Hong
Kong,
China
and
Europe.
Gray
was
started
over
10
years
ago
in
the
U.S.
(via
its
predecessor)
and
took
the
form
of
Gray
International
in
2013
as
the
result
of
the
networking
of
multiple
independent
practices
and
professionals.
Gray
provides
international
accounting
and
compliance
solutions
in
the
U.S.,
Americas,
Asia
and
Europe.
Gray
focuses
on
U.S.
accounting,
tax,
and
governmental
compliance
for
multinational
companies,
investors,
U.S.
persons
living
overseas
and
foreign
investors
and
companies
investing
in
or
moving
to
the
U.S.
Gray
also
consults
on
compliance
with
U.S.
laws
for
businesses
and
Iinancial
institutions
overseas
such
as
the
Foreign
Corrupt
Practices
Act
(FCPA)
and
the
Foreign
Account
Tax
Compliance
Act
(FATCA),
the
IRS
Offshore
Voluntary
Disclosure
Program,
and
the
Program
for
Non-­‐Prosecution
Agreements
or
Non-­‐Target
letters
for
Swiss
Banks.
Gray’s
principals,
partners,
and
employees
have
served
clients
worldwide.
Gray
has
ofIices
in
Geneva,
Hong
Kong,
Seattle,
Shanghai
and
plans
to
open
an
ofIice
in
Singapore
in
late
2013.
Gray’s
U.S.
public
accounting
Iirm
(Gray
CPA,
PC)
is
registered
with
the
U.S.
Public
Company
Accounting
Oversight
Board
and
is
a
member
of
the
American
Institute
of
CertiIied
Public
Accountants
and
the
Center
for
Audit
Quality.
For
more
information
about
us,
please
visit
us
at:
www.grayintl.com
International
Accounting &
Compliance

4. WHAT WE DO
OUR SERVICES
AUDIT AND ATTEST SERVICES
INTL. FORENSIC ACCOUNTING
U.S. TAX COMPLIANCE
U.S. FATCA COMPLIANCE
INTL. TAX STRUCTURING
U.S. FCPA COMPLIANCE
International
Accounting &
Compliance

5. WHERE WE WORK
GEOGRAPHIC AREAS OF EXPERIENCE
Greenland
Alaska
Iceland
Canada
USA
Bahamas
Mexico
Belize
Guatemala
El
Salvador
Cuba
Honduras
Nikaragua
Dom.
Rep.
Jamaica
Venezuela
Costa
Rica
Guyana
Panama
Columbia
Suriname
Fr.
Guyana
Ecuador
Brazil
Peru
Norway
Sweden
Russia
Great
Germany
Belarus
Ireland
Britain
Poland
Ukraine
Kazazhstan
France
Mongolia
Romania
Uzbekistan
Kyrgysistan
Italy
North
Korea
Spain
Portugal
Turkey
Tajikistan
Japan
Greece
Syria
Turkmenistan
China
South
Korea
Tunisia
Lebanon
Iraq
Iran
Afghanistan
Morocco
Bhutan
Israel
Nepal
Qatar
Algeria
Libya
Pakistan
Saudi
Westsahara
Taiwan
Egypt
Myanmar
Arabia
U.A.E
India
Laos
Eritrea
Oman
Mauritania
Bangladesh
Mali
Niger
Vietnam
Chad
Senegal
Yemen
Sudan
Cambodia
Burkina
Guinea
Philippines
Nigeria
Thailand
Ethiopia
Sierra
Leone
C.A.R.
Kamerun
Somalia
Malaysia
Liberia
Togo
Uganda
Ghana
Cote
d‘Ivoire
Gabun
D.
R.
Kenya
Congo
Indonesia
Tanzania
R.
Congo
Angola
Bolivia
Paraguay
Finland
Namibia
Zambia
Papua
New
Guinea
Mozambique
Zimbabwe
Botswana
Madagascar
Australia
Swaziland
South
Africa
Chile
Uruguay
Argendna
Lesotho
New
Zealand
International
Accounting &
Compliance

6. WHAT WE DO
OUR PRACTICE AREAS
International
Accounting &
Compliance

7. WHAT WE DO
OUR
PRACTICE
AREAS
AUDIT
AND
ATTEST
SERVICES
INTL.
FORENSIC
ACCOUNTING
U.S.
TAX
COMPLIANCE
Our
experienced
auditors
provide
extensive
experience
auditing
public
and
private
companies
in
the
developed
and
developing
markets.
Let
us
put
our
extensive
experience
operating
in
the
U.S.,
Asia,
Europe
and
the
Americas
to
work
for
you.
Our
forensic
accounting
services
are
designed
to
providing
vigilance
before
the
fact,
reconstructing
and
tracing
records
after
the
fact,
and
preparing
for
trial
once
the
Iindings
are
made.
Our
team
of
experts
are
available
for
worldwide
engagement.
U.S.
FATCA
COMPLIANCE
INTL.
TAX
STRUCTURING
Gray
provides
extensive
U.S.
tax
compliance
solutions
to
clients
worldwide.
We
work
with
individuals,
family
ofIices,
investors,
Iinancial
institutions,
multinational
companies
and
domestic
(U.S.)
businesses.
Let
us
guide
you
through
the
maze
of
complex
U.S.
tax
compliance.
No
single
piece
of
U.S.
legislation
will
have
a
larger
impact
on
foreign
Iinancial
institutions
and
intermediaries
in
the
next
5
years
as
FATCA.
Let
us
help
you
assess
how
this
will
impact
your
organization
and
how
to
implement
a
practical,
affordable
solution.
In
today’s
global
landscape
international
tax
structuring
and
planning
has
never
been
more
important.
From
transfer
pricing,
treaty
compliance,
withholding
minimization,
estate
planning
and
domiciliation,
to
pre-­‐residency
tax
planning
Gray
is
ready
to
help
you
navigate
this
difIicult
terrain.
U.S.
FCPA
COMPLIANCE
Widespread
globalization
brings
increased
risks
of
corrupt
practices,
and
correspondingly,
an
increase
in
FCPA
enforcement,
penalties
and
prosecutions.
Let
Gray
help
you
prepare
and
implement
appropriate
controls
to
protect
your
organization
from
violations.
International
Accounting &
Compliance

8. AUDIT AND ATTEST SERVICES
Through
our
public
accounting
Iirm
(Gray
CPA,
PC),
based
in
the
United
States,
we
provide
comprehensive
audit
and
attestation
services.
Gray
is
PCAOB
registered
and
has
deep
experience
auditing
and
consulting
for
both
private
and
public
companies
in
the
developed
and
developing
markets.
Our
audit
and
attestation
services
include:
PCAOB
AUDITS
EB-­‐5
LAWFUL
SOURCE
OF
FUNDS
REPORTING
PRIVATE
COMPANY
AUDITS
ANTI-­‐MONEY
LAUNDERING
CERT.
AGREED
UPON
PROCEDURES
COMPLIANCE
AUDITS
International
Accounting &
Compliance

9. INTERNATIONAL FORENSIC ACCOUNTING
International
business
requires
a
higher
level
of
vigilance.
Gray’s
international
forensic
accounting
solutions
are
performed
by
CPAs,
certiIied
fraud
examiners,
seasoned
auditors
and
investigators
with
deep
experience
operating
internationally.
We
provide
services
for
business
acquisitions,
divestitures,
investments,
divorce,
legal
proceedings,
U.S.
OVDI
submissions,
and
fraud
examinations.
Our
forensic
solutions
include:
BANK
ACCOUNT
RECONSTRUCTION
ASSET
TRACING
DUE
DILLIGENCE
FOREIGN
ACCT.
RECONSTRUCTION
(OVDI)
FRAUD
EXAMINATION
EXPERT
WITNESS
(CONS.
+
TESTIFYING)
International
Accounting &
Compliance

10. U.S. TAX COMPLIANCE
Gray
provides
extensive
U.S.
tax
compliance
solutions
clients
worldwide.
Gray
has
extensive
experience
working
with
individuals,
family
ofIices,
investors,
Iinancial
institutions,
multinational
companies
and
domestic
(U.S.)
businesses.
As
experienced
business
people,
our
tax
professionals
provides
tax
compliance
services
that
are
business
appropriate
and
Iit
with
both
the
requirements
and
your
style
of
doing
business.
Our
U.S.
tax
compliance
solutions
include:
U.S.
DOMESTIC
TAX
COMPLIANCE
OFFSHORE
VOLUNTARY
DISCLOSURES
TRANSFER
PRICING
TAX
CONTROVERSY
AND
AUDIT
U.S.
TAX
OPINIONS
PASSIVE
FOREIGN
INVESTMENT
COMPANIES
International
Accounting &
Compliance

11. U.S. FATCA COMPLIANCE
Gray
believes
that
FATCA
Compliance
will
be
one
the
the
biggest
compliance
concerns
for
foreign
Iinancial
institutions
and
intermediaries
in
the
coming
years.
FATCA
regulations
essentially
require
that
Iinancial
institutions
outside
of
the
U.S.
become
an
unpaid
reporting
arm
of
the
U.S.
Treasury.
Non-­‐compliance
results
in
a
punitive
withholding
regime
or
lost
market
opportunity,
neither
of
which
is
an
attractive
option.
Due
to
the
wide-­‐reaching
implications
of
FATCA
almost
all
foreign
Iinancial
institutions
and
intermediaries
will
need
to
make
a
well
considered
decision
about
implementation.
Gray
assists
senior
executive
teams
assess
and
implement
the
FATCA
requirements
by
providing
the
following
services:
IMPACT
STUDIES
PROJECT
PLANNING
IMPLEMENTATION
PLANNING
TRAINING
IMPLEMENTATION
International
Accounting &
Compliance

12. INTERNATIONAL TAX STRUCTURING
Today
we
operate
more
on
the
global
landscape
than
ever
before
and
international
tax
structuring
and
planning
has
never
been
more
important.
From
transfer
pricing,
fund
structuring,
inbound
and
outbound
investment
considerations,
treaty
compliance,
withholding
minimization,
estate
planning
and
domiciliation,
to
pre-­‐residency
tax
planning
Gray
is
ready
to
help
you
navigate
this
difIicult
terrain.
Gray’s
international
tax
structuring
services
include
the
following:
TRANSFER
PRICING
INTELLECTUAL
PROPERTY
DOMICILIATION
INBOUND/OUTBOUND
INVESTMENTS
PRE-­‐RESIDENCY
TAX
PLANNING
TREATY
COMPLIANCE
INTL.
ESTATE
PLANNING
International
Accounting &
Compliance

13. U.S. FOREIGN CORRUPT PRACTICES ACT
COMPLIANCE
Congress
enacted
the
U.S.
Foreign
Corrupt
Practices
Act
(FCPA)
in
1977
in
response
to
revelations
of
widespread
bribery
of
foreign
ofIicials
by
U.S.
companies.
The
FCPA
prohibits
U.S.
persons
and
businesses
(domestic
concerns),
U.S.
and
foreign
public
companies
listed
on
stock
exchanges
in
the
U.S.
or
which
are
required
to
Iile
periodic
reports
with
the
U.S.
SEC,
and
certain
foreign
persons
and
businesses
acting
while
in
the
territory
of
the
United
States
from
making
corrupt
payments
to
foreign
ofIicials
to
obtain
or
retain
business.
The
accounting
provisions
require
issuers
to
make
and
keep
accurate
books
and
records
and
to
devise
and
maintain
and
adequate
system
of
internal
accounting
controls.
The
U.S.
Department
of
Justice
and
the
Securities
and
Exchange
Commission
share
FCPA
enforcement
authority,
and
they
regularly
work
with
law
enforcement
partners
such
as
the
FBI
and
the
Department
of
the
Treasury.
Fines
for
violations
of
the
provisions
can
be
in
the
tens
and
hundreds
of
millions
of
dollars,
and
the
SEC
and
U.S.
DOJ
have
greatly
increased
their
investigation
and
enforcement
of
these
provisions.
Gray’s
FCPA
compliance
solutions
include
the
following:
ANTI-­‐CORRUPTION
PROGRAMS
IMPLEMENTATION
THIRD
PARTY
MONITORING
FCPA
INVESTIGATIONS
International
Accounting &
Compliance

14. CONTACT US
Gray
welcomes
your
questions,
comments
and
inquiries
and
would
like
the
opportunity
to
serve
you.
Address:
U.S.
International
OfIice
(Handling
U.S.
Tax
and
Compliance
for
International
Business)
Attn:
Jeremy
Stobie,
CPA,
CFE
th
Street
10900
NE
8
Suite
1000
Bellevue,
WA
98004
Phone:
+
001
425.999.3685
xt
10
Website:
www.grayintl.com
E-mail:
info@grayintl.com
International
Accounting &
Compliance