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Tax Planning for Foreign Service Providers with U.S. Clients
You are a non-U.S. consultant, web developer, programmer, or other service provider, and you are hired by a U.S. client.
This month’s International Tax Lunch walks you through the U.S. tax laws that apply to you. What will you pay? What paperwork will you file? What can you do to reduce or eliminate tax, paperwork, or both? We will discuss using transfer pricing techniques — they can work, even micromultinational businesses, like a one-person service provider.
Presenter: Phil Hodgen
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The passive foreign investment company (PFIC) rules are mechanical tests. An operating company that is actually doing business can fall afoul of them in the right circumstances. This session discusses some of the circumstances that may make an operating company a PFIC and what to spot to see if they are PFICs.
Presenter: Haoshen Zhong
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Nongrantor trusts (foreign or domestic) have significant tax advantages for foreign investors in U.S. real estate. But these tax advantages come at a cost. Trusts are complicated and expensive to set up and operate. The investor loses control over the trust assets. The capital — and the capital gain — now belongs to the trust, not the investor.
In this one-hour session, Phil will walk you through a typical real estate holding structure for a foreign investor. When do you select a foreign or domestic trust? How do you design the trust for the desired tax results?... continue reading
Presenter: Haoshen Zhong
You set up a family trust with your spouse. And now you want to move — across the US border. This session discusses what happens to your trust when you change between a US resident (or citizen) and a nonresident alien.
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