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Inbound Immigration: Tax and Business Considerations

Cross-Border Employment Issues, M&A Abroad, Treaty Benefits, Residency and Permanent Establishment Rules

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Tuesday, July 22, 2025

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, June 27, 2025

or call 1-800-926-7926
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This webinar will review the essential factors foreign businesses should consider before locating in the U.S. Our panel of global tax structuring experts will point out immigration issues in M&A transactions, discuss viable pathways for foreign personnel transferring to the U.S., and review the residency and permanent establishment rules for global businesses and their workforces. They will offer advice to reduce the overall tax impact of the move made by these entities and their employees.

Description

Pre-planning for immigration to the U.S. is essential to mitigate the U.S. tax bite and facilitate entry into the country. Foreign companies with permanent establishments (PEs) are subject to U.S. taxation. Activities from a fixed place of business in the country constitute a PE, while a subsidiary might avoid this classification. Businesses relocating employees from their home country need to consider the tax implications of the move to avoid potential double taxation of income and social security taxes on wages paid abroad. Companies acquiring foreign nationals through M&A transactions may want to ensure they are a successor-in-interest to preserve visa status for these employees.

Under U.S. tax law, determining whether individuals are residents or nonresidents dictates whether they are taxed on worldwide income (resident) or only U.S. source income (nonresident). Green card holders and those who satisfy the substantial presence test are considered residents of the U.S.

There are steps mobile taxpayers, multinational enterprises, and their advisers can take to facilitate a move to the U.S. Treaty benefits, residency planning, transferring or stepping-up the basis in assets, and other measures can reduce a foreigner's tax burden and ease the transition to the U.S.

Listen as our panel of business immigration attorneys discusses tax and business considerations arising from the inbound immigration of mid-to-large corporations to the U.S.

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Outline

  1. Residency concepts for tax and immigration
  2. PE risks for foreign companies
  3. Global mobility and cross-border employment structures
  4. M&As involving foreign nationals
  5. E-1 and E-2 visas for international entrepreneurs

Benefits

The panel will cover these and other critical issues:

  • Strategies for limiting U.S. tax exposure
  • Utilizing benefits of U.S. tax treaties with foreign countries
  • Implications of sourcing employee benefits and taxation in the U.S. vs. abroad
  • Immigration issues in M&A transactions

Faculty

Slipman, Jared
Jared C. Slipman
Attorney
Obermayer Rebmann Maxwell & Hippel

Mr. Slipman is an attorney in Obermayer’s Business & Finance Department. He focuses his practice on tax...  |  Read More

Staller, Shaun
Shaun Staller
Partner
Obermayer Rebmann Maxwell & Hippel

Mr. Staller is a business immigration attorney with broad international experience who counsels individuals...  |  Read More

Attend on July 22

Early Discount (through 06/27/25)

CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.

Cannot Attend July 22?

Early Discount (through 06/27/25)

CPE credit is not available on downloads.

CPE On-Demand

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