Entity Classification Election
Entity Classification Election Following our previous discussion about...
Check-The-Box Regulations
Check-The-Box Regulations Also known as the Regulations, the...
How to Avoid the Net...
How to Avoid the Net Investment Income Tax...
Sole Proprietorship vs LLC
Sole Proprietorship Vs. LLC: What's The Difference? It...
Grantor vs Trustee
Grantor vs. Trustee When dealing with a grantor...
What are the U.S. Estate Tax Implications for Non-Resident Aliens Holding U.S. Assets?
It is possible for a “non-resident alien” (i.e. a person who does not live in the U.S. and who is not a U.S....Read more
Restructuring your US operations – Part 2: US corporate reorganization relief
As with the Income Tax Assessments Acts, the Internal Revenue Code (IRC) provides for tax relief (“nonrecognition”) for corporate reorganizations (under sections 354-368)....Read more
Restructuring your US operations – Part 1: why, and how you would convert an LLC to an Inc.
Many Australian business owners often fund their initial expansion into the US market through a limited liability corporation or “LLC”. An LLC is...Read more
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...Read more
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...Read more