Category: Featured Articles

Entity Classification of foreign companies and trusts in the US and penalties associated with getting it wrong!

In our experience the area that carries the most risk is the failure of a taxpayer to properly classify an Australian entity under US law....

Read more

Penalties for non-disclosure of foreign financial assets

The FBAR, together with the FATCA regime, requires U.S. taxpayers to disclose foreign financial assets subject to certain threshold requirements. Due to the cross boarder...

Read more

The Multilateral Instrument and The Changing Framework of Permanent Establishment

On November 2016 over 100 jurisdictions concluded negotiations on the multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting....

Read more

Wine, Wine, I need more Wine: While Trump’s Tax Reform is Delivering on The Election Promises Made to his Base, the Tax Reform has a Biting Impact on Foreign Businesses!

In my Whitepaper “United States Entity Considerations in the Trump Era”I discussed the opportunities that will exist for companies that wish to headquarter themselves in...

Read more

Global innovators are paying for Trumps Tax Reform? Have you received the invoice for your share?

In the Whitepaper “United States Entity Considerations in the Trump Era” we discussed headline tax reform but we did not discuss the deep issues, like...

Read more

The US will not be my 1st Choice as a holding company jurisdiction, will it be yours?

In a whitepaper, that I had published in the Tax Specialist in April of 2018, I made the bold assertion that people may start looking...

Read more

Should I fund my US subsidiary with debt or equity?

In our US market entry guide we talked about flow through taxation and how it can be positively or adverslye impact a foreign owned business....

Read more

UNDERSTANDING SALES TAX IN THE US

In our US market entry guide we discuss entity choice and how those choice may benefit or adversely impact you as you grow. Understanding state...

Read more

Part 3 –Market Entry Guide: What is better choice for foreign businesses, Corporations or LLCs? How do I choose?

Choosing between a corporation and a LLC is a difficult task because it requires business owners to trade off benefits. To quote Simon Sinek ‘you...

Read more

Part 2 – Expanding into the US – Market Entry Guide: What are the entity options?

Each year hundreds of thousands of foreign businesses establish US operations. While entity choice may require consideration of corporations, Limited Liability Company’s (LLCs), Limited Liability...

Read more
1 2 3 4