International Tax Structures
For American Living Aboard
A collection of tax charts that visually detail outbound International Tax transactions in relation to the United States tax system. This book is designed as a primer for understanding the fundamental concepts of international tax transactions for U.S. citizens living abroad or conducting offshore transactions.
By Marcus Marcial
Visual solutions for tax optimization…
Foreign Earned Income Exclusion
Foreign Earned Income is exempt from U.S. taxation (up to certain limits) for salaries and wages received for services while working in a foreign country during which your tax home is in a foreign country, and either the bona fide residence test or the physical presence test is met.
For optimal tax savings, certain considerations must be made, and tax calculation to ensure you are claiming the full benefit of the exclusion.
FEIE Structure #1: Offshore-Consultant-Foreign-Salary-from-a-BVI-Ltd.
FEIE Structure #4: Married Filing Jointly Offshore Consultants Foreign Salary from S-Corporation
Foreign Tax Credit
A Foreign Tax Credit is generally applied to mitigate the potential for double taxation dollar-for-dollar. To determine the proper use of the credit, a compliance review and International Tax Structure may be necessary to determine the proper application under the law.
FTC Structure #1: Offshore Salary Earner Netherlands Higher Foreign Rate
FTC Structure #5: Foreign Tax Credit for Costa Rican Rental Property U.S. Higher Rate
Global Intangible Low Taxed Income
Global Intangible Low-Taxed Income (GILTI) is a category of income to target profits earned by controlled foreign corporations (CFCs) that are subject to low foreign taxes. U.S. shareholders of CFCs must include a portion of the CFC’s income in their current U.S. taxable income, even if it isn’t distributed. To better understand the tax implications and calculations, an International Tax Structure can get you on the right track going forward.
GILTI Structure #1: C-Corporation Section 250 Deduction India Services
GILTI Structure #3: GILTI Inclusion for U.S. Individual With 962 Election
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.