Category: Peter Harper

Double Tax on U.S sourced Capital Gains

The ATO have successfully argued in the Federal Court of Australia in the case of Burton v Commissioner of Taxation [2019] FCAFC 141 that only...

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What does ‘two-up’ have in common with selling Australian real estate while living in the US?

I am often asked how can a capital gain associated with your main residence that is tax-free in Australia be taxable in the U.S.? For...

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US Market Entry Guide: Top 3 business drivers that should impact entity choice

If you have a specific US market entry tax question please complete the ‘Have a tax question?’ form on the right hand of the page...

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US Market Entry Guide: What are my entity options?

If you have a specific US market entry tax question please complete the ‘Have a tax question?’ form on the right hand of the page...

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Understanding Sales Tax in the US

If you have a specific US market entry tax question please complete the ‘Have a tax question?’ form on the right hand of the page...

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We will be funding out US expansion with debt funding from our parent entity – are there any restrictions for claiming interest expenses as a deduction against income?

The difference between debt and equity funding Opening a United States-based corporation to expand your business can provide an excellent revenue stream and worth the...

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I Want to Start a Business in the United States. What the Are Best States for business?

Expanding and diversifying your business interests in the United States is a great way to take advantage of one of the biggest markets in the...

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When I move to the U.S. when do I become a tax resident? Is my U.S. visa important?

Like many countries, United States tax law is complicated, especially for non-citizens who live and/or work in the country. Expats in the United States need...

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I don’t live in the US – why am I subject to US tax?

Author: Peter Harper How can the US tax me – doesn’t the tax treaty stop me from being subjected to Double Tax? In my last...

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When will an Australian Trust be a Grantor Trust Under the Internal Revenue Code of 1986 (Code)?

Author: Peter Harper In many countries outside of the U.S. discretionary forms of trusts are used as both business planning and estate planning tools because...

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