Nonresident business enterprises coming into the United States are subject to tax ramifications wholly distinct from how United States taxpayers are taxed. Evaluation of how to structure American activities is critical – i.e., whether to form a separately taxable United States subsidiary or conduct direct United States activities. United States businesses with multinational activities can […]

Taxpayer who have previously failed to properly report multinational activities or holdings – in many/most cases for innocuous reasons – enormously benefit from amending prior filings to rectify these issues (to minimize penalty exposures). Fortuitously, the Service offers multiple disclosure programs, some of which are specifically designed for international tax issues. Expert analysis with regards […]

Complex tax compliance requirements arise – both for information reporting and income inclusion purposes – for multinational activities. Expertise on these assorted requirements is needed to properly protect taxpayers from American penalty imposition – with penalties for specified failures carrying enormous financial penalties.

Pre-immigration tax planning is focused on current nonresident individuals who, as a result of anticipated changes in their American immigration status, will become United States taxpayers. It is absolutely critical to implement proper planning during the pre-residency period – both for income tax purposes and estate and gift tax purposes. Planning focuses on income acceleration […]

United States taxpayers with multinational activities- and holdings are subject both to special American tax provisions for foreign-sourced income and innumerous American information reporting requirements for foreign activities. The Internal Revenue Service is increasingly aggressive in assessments for failures to properly report multinational activities. Where this occurs, expertise both with American international tax rules and […]

Nonresidents are subject to statutory/regulatory tax rules by the United States; however, these (often punitive) tax ramifications can be modified where the nonresident (whether an individual or a corporate entity) is a tax resident of a country which maintains a treaty with the United States. Where this is the case, treaties provide assorted tax relief; […]

Nonresidents making U.S. investments – whether in real estate holdings, stock and securities, partnership interests, or a multitude of other options – face exposures both for income tax and estate and gift tax purposes. Proper investment structures are normally investment-specific, with home country tax ramifications also a paramount consideration.

Individuals not domiciled in the United States but who maintain American holdings can be subject to enormous American estate and gift tax exposures. Estate and gift tax is assessable based on fair market value of holdings at time of transfer, and only a $60,000 exclusion is provided for estate tax purposes (with no specific exclusion […]

Nonresidents can be taxable by the United States under assorted circumstances – from ongoing. Significant American connections to passive activities or connections that have ceased long ago. United States taxpayers with multinational activities or holdings are subject to tax by the United States on worldwide income. Mitigation of American tax ramifications can be achieved through […]

“International” tax matters are often intertwined with more domestic-oriented tax considerations – particularly for nonresident taxpayers, who can be subject to American tax rules both specific to their status as nonresidents as well as tax provisions applicable to any taxpayer. Familiarity with all aspects of United States tax rules is a necessity in representing international […]