The Code Fails To Define A “U.S. Trade Or Business,” Even Though You’re On The Hook For Paying Taxes On It
As mentioned in our prior post, Even Nonresident Aliens may be Taxable in their U.S.-Sourced Income, a nonresident alien will be liable for... Read more
Entity Classification Of Foreign Companies And Trusts In The US And Penalties Associated With Getting It Wrong!
In our experience the area that carries the most risk is the failure of a taxpayer to properly classify an Australian entity under... Read more
Penalties For Non-Disclosure Of Foreign Financial Assets
The FBAR, together with the FATCA regime, requires U.S. taxpayers to disclose foreign financial assets subject to certain threshold requirements. Due to the... Read more
The Multilateral Instrument and The Changing Framework of Permanent Establishment
On November 2016 over 100 jurisdictions concluded negotiations on the multilateral convention to implement tax treaty related measures to prevent base erosion and... Read more
