U.S. Taxation of Foreign Individuals and Businesses: IRS Compliance and Enforcement
Impact of Tax Treaties, ECI vs. FDAP Income, Reporting Requirements, Exemptions, Deductions, Tax Credits
Note: CPE credit is not offered on this program
A live 90-minute premium CLE video webinar with interactive Q&A
This CLE/CPE course will provide tax counsel and compliance professionals guidance on U.S. tax rules, reporting requirements, and available tax planning mechanisms for foreign individuals and businesses. The panel will offer approaches for determining taxpayer classification and engaging in U.S. trade or business under current tax law, identifying and reporting income subject to U.S. income tax, and understanding the impact of tax treaties, available exemptions, and deductions. The panel will also offer U.S. tax planning tips for foreign individuals and businesses with activities within the United States.
Outline
- U.S. tax presence and residency rules
- Tax issues for non-U.S. individuals
- Tax issues for non-U.S. businesses
- Compliance and reporting challenges for taxpayers
Benefits
The panel will review these and other key issues:
- What is the impact of tax presence and residency of individuals and businesses?
- What is the impact of the application of the "substantial presence test"?
- What are the key issues stemming from the application of the "physical presence test" for purposes of determining U.S. trade or business or permanent establishment standards?
- What allocation issues are present?
- What are the steps to overcome regulatory and compliance challenges?
Faculty
Arianne R. Plasencia
Partner
McDermott Will & Emery
Ms. Plasencia focuses her practice on US & international tax and estate planning matters. She provides... | Read More
Ms. Plasencia focuses her practice on US & international tax and estate planning matters. She provides international and US income, gift, and estate tax planning for entities and high-net-worth individuals. Ms. Plasencia works closely with multijurisdictional families and advises on inbound investment planning. As part of this work, she counsels individuals investing in the United States, trustees of trusts with US beneficiaries, individuals moving to and from the United States, and families with members residing in multiple jurisdictions.
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Gregory M. Weigand
Partner
McDermott Will & Emery
Mr. Weigand focuses his practice on complex domestic and international tax matters for multinational companies, closely... | Read More
Mr. Weigand focuses his practice on complex domestic and international tax matters for multinational companies, closely held businesses, investment funds and family offices and high-net-wealth individuals. He advises US and foreign-based publicly traded and privately held companies on domestic and international mergers and acquisitions, financing transactions, and global restructuring transactions. Mr. Weigand regularly advises on the tax aspects of complex domestic and international transactions and the formation, structuring, and operation of private equity funds and family offices. He is experienced in negotiating, drafting and documenting transactions involving corporations, partnerships and cross-border entities. In addition, Mr. Weigand regularly represents international businesses and individuals with structuring and reorganizing their US operations and investments, including a significant amount of US real estate-based transactions such as the purchase and sale of commercial real estate and hospitality-related assets.
CloseEarly Discount (through 05/30/25)