The federal income tax on inbound international transactions: traps for the unwary

Article Abstract:

Non-resident aliens and foreign corporations doing business in the US must consider tax issues affecting inbound transactions including categorization of income as fixed, determinable, annual or periodic (FDAP), or as effectively connected with the conduct of a US business (ECI). Passive FDAP income includes interest, dividends, rents and royalties. ECI income is derived from personal services, sales or exchanges of personal property, and certain capital gains. The gains from disposal of a US real property interest, the branch profits tax, and transfer pricing are discussed.

Non-resident aliens, Nonresident aliens, international

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Hybrid entities: practical application under the check-the-box regime

Article Abstract:

New opportunities for structuring overseas entities have existed since the Dec 1996 IRS release of the efficiency-creating check-the-box regulations for corporate entity classification. Branch treatment can be afforded single-member entities, and entities with two or more members can be treated as corporations or partnerships upon election. Suggestions for designing and maintaining these hybrid entities are provided, as well as tax treaty implications and other hybrid related issues.

Limited liability companies, Partnership, Partnerships

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