International Tax Preparation & Consultation

Foreign Owned LLC Structures

Tax Structures for the Foreign Owned LLC

 

Tax Structures of U.S. Foreign Owned LLCs

A guidebook that takes a simplistic approach to explaining the U.S. tax implications of Foreign-Owned Limited Liability Companies.

By Marcus Marcial

Download the Full Guidebook (PDF)
 

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. Limited Liability Companies. 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 LLC Structure #1 PDF: Non-Resident Alien U.S. LLC Foreign Consultant

Foreign Owned LLC Structure #2 PDF: Argentinian Resident with SMLLC E-Commerce China Direct

Foreign Owned LLC Structure #3 PDF: Bulgarian NRA LLC Partnership Software Sales

Foreign Owned LLC Structure #4 PDF: German LLC Partners No USTOB ECI Reduced Withholding

Foreign Owned LLC Structure #5 PDF: Real Estate Rental ECI Election No Withholding

Foreign Owned LLC Structure #6 PDF: Co-Ownership Real Estate Sale FIRPTA Withholding

Foreign Owned LLC Structure #7 PDF: Tax Treaty Exemption E-Commerce SMLLC Belgian Permanent Establishment

Foreign Owned LLC Structure #8 PDF: Belgian NRA LLC Owner with Office Permanent Establishment

Foreign Owned LLC Structure #9 PDF: Netherland NRA Royalties E-Commerce and Events from SMLLC

Foreign Owned LLC Structure #10 PDF: Romanian NRA SaaS Digital Sales and E-Commerce from DE LLC

 
 
 
 

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.

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