Mastering the Effectively Connected Income Rules for Foreign Persons Engaged in Inbound Transactions
Navigating Differing Tax Treatment for ECI and FDAP Income, Withholding Requirements, Available Elections and Other Planning Options
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers and professionals with a deep dive into the effectively connected income (ECI) rules as they apply to inbound transactions engaged by nonresident alien taxpayers in the United States. The panel will discuss differing tax treatment for ECI and income that is fixed, determinable, annual or periodic (FDAP), outline the withholding requirements, and detail available elections and other planning considerations in determining whether inbound income qualifies as ECI.
- Definition of ECI
- Trade or business, partnerships, beneficiary of trust engaged in business
- ECI contrasted with FDAP
- Form 1120-F
- Withholding requirements and exemptions
- Case study illustration
The panel will discuss these and other key issues:
- What are the criteria for qualifying income as “effectively-connected”?
- What are the differences in tax reporting, rates and withholdings between ECI and FDAP?
- What are the criteria for determining a nonresident alien taxpayer?
- What is the 871 election for real estate income, and how does it work in practice?
- What are the planning options to minimize tax on ECI?
Daniel R. Blickman
Mr. Blickman has substantial experience in a wide range of federal and state tax issues. He represents clients in... | Read More
Mr. Blickman has substantial experience in a wide range of federal and state tax issues. He represents clients in all aspects of mergers and acquisitions, issuance of securities, reorganizations, redemptions, and liquidations, both domestic and international, using corporations, partnerships, and joint venture structures. He also has extensive experience in the formation of investment funds, real estate transactions, compensation issues, cross-border investments (both in-bound and out-bound), securitizations, and capital market issues, including swap agreements.Close
Jeffrey M. Rosenfeld, Esq.
Mr. Rosenfeld concentrates his practice in the area of business tax law. He counsels clients in a broad array of tax... | Read More
Mr. Rosenfeld concentrates his practice in the area of business tax law. He counsels clients in a broad array of tax matters including domestic and international tax matters, state and local tax planning, tax-efficient structuring of domestic and international mergers, acquisitions, divestitures, reorganizations, spin-offs, redemptions and liquidations, formation, operation and acquisition of Subchapter S Corporations, partnerships and limited liability companies. He counsels clients regarding undeclared foreign bank accounts, including “FBAR” reporting obligations.Close
James K. Sams
Principal, International Corporate Tax
Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical... | Read More
Mr. Sams is attached to the firm's International Corporate Tax Services Practice, providing high-level technical assistance and tax consulting to clients on inbound and outbound tax issues. He previously served in several roles with the IRS Office of Chief Counsel.Close