Indian entities and U.S. taxation: Operating in the U.S. as a branch or subsidiary

The business activities of an Indian entity operating in the U.S. may or may not create a physical presence.  Before expanding your Indian operations in...

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Indian entities and U.S. taxation- Part II

Indian entities generating revenue from conducting trade or business within the U.S. have effectively connected income (ECI) and taxable in the U.S.  Broadly, ECI may...

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Indian entities and U.S. taxation – Part I

An Indian entity doing business in the U.S., unlike a U.S. incorporated entity, is generally taxable in the U.S. ‘on its taxable income which is...

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The Australian Bushfires – how you can help support Australia while ensuring that donations are tax deductible in the United States.

The bushfires are having disastrous consequences across Australia. It is with great sadness that each day we witness, from afar, the destruction of land, homes,...

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Woodpoint Capital: 2020 Investment Letter

The recession debate: A recession occurs on average every seven years. But in the US, the bull market is roaring into its 11th consecutive year....

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Is your Australian related party loan “debt” or “equity” for US tax purposes?

If you are attempting to determine how your related party loan could characterized for US tax purposes, there are a number of considerations you need...

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Is your Australian trust a “grantor trust” for US tax purposes?

The US taxes a “United States Person” (defined to include a ‘US resident’ or a citizen) on a worldwide basis, whereas non-US persons are taxed...

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A nonresident individual married to a U.S. citizen may be required to file a U.S. tax return if…

Generally, the number of days an individual spends in a country is one of the important determinants of taxability in such country. But it is...

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The 2019 OECD Tax Statistics – how does the US and Australia compare?

The OECD has released its annual Revenue Statistics Report comparing the tax data for all OECD countries . The OECD Tax Statistics The 2019 Report...

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Rules of POEM – Part II

An earlier blog on POEM started with a discussion on the determinants of residential status of a foreign corporation in India. The Indian tax law...

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