Proper understanding of the U.S. tax rules and regulations is necessary in order to successfully conduct a business in the U.S. It is important to carefully plan and analyze the legal and fiscal issues of specific business structure. These issues can vary depending on the purpose of the entrepreneur and development plans. In particular, businesses’ need for external financing, growth forecast, activities, and business’ desire to raise capital through shareholders can change business’ legal and fiscal issues.
Income of a foreign company who conduct business in the U.S. is treated as income from sources within the United States. However, depending on the characterization of U.S. business (foreign branch, agent, or U.S. company), U.S. sourced income can be categorized as either Effectively Connected Income or FDAP income, which are taxed differently.
THEVOZ Attorneys has attorneys who are well versed in U.S. tax law and able to provide advice to its clients on their business development and commercial activities in the U.S. in particular in the following areas:
- Sourcing rules
- Withholding tax on payment to non-residents
- Withholding agent and payee obligations
- Income tax treaty