In the U.S., business entities are formed on a state level.  This means that the taxpayer must choose a state to setup the business.  Each state has unique rules for formation, corporate [...]

Today I was listening to ESPN radio, two hosts were discussing an NFL team moving to London.  They said it would never happen because the player would have to pay the 45% maximum rate in England, [...]

Prior to the Tax Cuts and Jobs Act, in order to qualify as a controlled foreign corporation (CFC), U.S. persons had to control the foreign corporation for an uninterrupted period of 30 days.  [...]

While we have not heard of any official policy from the IRS, we have been witnessing an unsettling trend.  In the past month we have had three clients who owed taxes received unexpected visits [...]

There are several options for filing status when a U.S. person is married to a non-U.S. person.  First, the standard method is to file as married filing separately.  This is the easiest option as [...]

One of the biggest changes the 2017 Tax Cuts and Jobs Act (TCJA) enacted in the international tax arena was section 951A, also known as the Global Intangible Low-Taxed Income (GILTI). GILTI [...]

The GILTI laws apply to far more taxpayers than expected, require long detailed calculations, and after all that work could likely result in no tax.  However, the cost of ignoring the [...]

In general, there are not any restrictions on foreigners owning U.S. businesses.  The corporation, LLC, or other business entity files its formation documents with the appropriate state [...]

In general, foreign owned businesses are taxed to their U.S. owners as if they were setup in the U.S.  Therefore, it is very important to determine what the business would be considered for U.S. [...]

We had a very fun and successful trip to Hong Kong and China meeting friends and colleagues, seeing the sights, making presentations, and spending time together.  It was a rewarding experience to [...]