Tax Structures of U.S. Foreign Owned Corporations
A guidebook that takes a simplistic approach to explaining the U.S. tax implications of Foreign-Owned Corporations.
By Marcus Marcial
Visual solutions for tax compliance…
Concepts Covered
This book is designed as a primer for understanding the fundamental concepts of international tax transactions for Foreign-Owned U.S. Corporations. Concepts covered include; Income Sourcing, Taxation of Individual Non-Residents in reference to Ownership of an LLC (in Limited Circumstances), Fixed Determinable and Periodic (FDAP) Withholding Tax, Determination of Effectively Connected Income (ECI), Tax Treaty Exemptions, Tax Treaty Special Withholding Tax Rates and Preliminary Concepts of Permanent Establishment.
Foreign Owned Corporation Structure #1 PDF: Foreign-Owned U.S. Corporation Danish Resident Dividend Withholding
Foreign Owned Corporation Structure #2 PDF: Non-Resident Salary and Dividends from C-Corporation
Foreign Owned Corporation Structure #3 PDF: Mexican Resident Contractor as C-Corporation Shareholder
Foreign Owned Corporation Structure #4 PDF: Capital Injection and Dividend Withholding for Foreign-Owned U.S. Corporation Belgian Resident
Foreign Owned Corporation Structure #5 PDF: Branch Profits Tax from SMLLC Amazon Sales Panama
Foreign Owned Corporation Structure #6 PDF: Isle of Man E-Commerce C-Corporation with Transfer Price Agreement
Need to Plan Your Own Structure?
Work with us to develop tax charts that visually detail inbound and outbound International Tax transactions in relation to the United States taxing system.
With a given scenario, the deliverable will highlight the flow of income, expenses, other cash distributions, and summarize the tax implications and filing compliance.
Book an appointment to schedule a call for a tax structure consultation. Also feel free to send me a message before the call if not in communication already.