Inbound Planning
Services
Inbound (Foreigner Persons and Businesses Investing in the US)
Advising foreign businesses on how to expand into the US in a tax-efficient manner requires expertise in U.S. tax law and a holistic approach focused on integrating US tax planning options with home country ownership and tax rules. This is even more important after recent U.S. tax reform. Prager Metis professionals can help you smoothly navigate the significant changes in tax laws under recent US tax reform and so that you confidently enter the U.S. market. Our approach ensures that you will receive tax planning advice that is aligned with your needs and objectives and that results in maximum tax efficiency.
Inbound Services:
-
U.S. taxable presence assessment for limited
US activities such as market research, solicitation, storage and logistics
- Tax efficient set up of US business
- U.S. entity selection, including US branch, partnership, limited liability corporation, S corporation or C corporation
- Advice on the impact of recent US tax reform as it relates to existing and proposed ownership structures and operationsAdvice on the impact of recent US tax reform as it relates to existing and proposed ownership structures and operations
-
Advice on US branch operations, including
branch profits tax and branch level interest
- Advise on the use of debt vs equity
- Advice on tax efficient supply chain and intercompany transactions
- Repatriation planning
-
US withholding on dividends, interest
and royalties
- Double tax treaty planning
-
Planning for US real property investment that minimize tax on both current income and
capital gains.
- Foreign tax credit planning
- Planning for acquisitions, dispositions and liquidations
- Transfer pricing services, including planning, benchmarking and documentation
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