There are various rules that require a US person that owns assets abroad or conducts business abroad to carefully meet the foreign filing requirements. US Tax Reform in 2017 significantly modified the US international tax rules that directly impact US business owners with international operations or investments. We advise US business owners relating to their US or global businesses. This includes US and international tax planning, and compliance with various reporting requirements. For example applicability of CFC, PFIC, GILTI, international tax treaties, foreign tax credits, preparing various forms to be filed.
Foreigners doing business in the US or investing in the US (e.g. real estate, stocks) are subject to US tax consequences, including US tax filing requirements, potential US withholding tax consequences.
We assist foreigners stay upto date with their US tax obligations and overall tax planning to optimise post tax returns
- Advise US business owners who have foreign operations to optimize their post-tax returns and meet their US tax reporting requirements
[E.g. Advise US business owner who exports goods and services to foreign countries and has foreign presence (i.e.. through companies or agents) on tax planning taking into account various considerations such as US foreign tax credit rules, international tax treaties, foreign country tax rules. In addition, preparing and filing various forms with the IRS that are required to be filed for international operations]
- Advise US investors in foreign corporations, foreign partnerships to structure their investments in most tax efficient manner
[E.g. Advise US investor who is an investor in a foreign Venture Capital Fund, Private Equity Fund, on the tax planning opportunities and international tax compliance requirements]
- Advise US investors who are picking up a majority or minority investment into a foreign business owned and operated by family or friends
[E.g. Advise US investors to structure their investments into foreign family/friends owned real estate, or technology business]
- Advise foreign business owners proposing to establish a presence in the US, or having an established presence
[E.g. US has pretty complex rules as it relates to foreigners establishing a US presence, and tax planning becomes increasingly important to mitigate high US taxes, and minimizing filing requirement. Foreign businesses willing to expand footprint in the US (e.g. Food distributor wanting to sell products across US), should carefully evaluate possible tax planning options based on their business strategy and business model.
- Advise foreign investors who make private investments in the US (e.g. investing in family/friend's US business). Careful planning is needed to look at the international tax treaties, US taxes and US tax filing requirements before making such investments to optimize post tax returns
- Foreign investors selling US real estate. US has unique tax rules as it relates to dealing in US real estate, that should be carefully assessed before dealing in US property
- Pre-immigration tax planning. Advise foreigners planning to settle in the US in their pre-immigration tax planning and US reporting requirements