
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

Indian entities and U.S. taxation: Income not effectively connected to the U.S.
U.S. federal tax law categorizes income earned by foreign corporations in the U.S.: - effectively connected income (ECI) with U.S. trade or business;... Read more

Key considerations for U.S. investors on abolition of dividend distribution tax in India
The memorandum to Indian Union Budget 2020-21 (Budget 2020) states that the present-day dividend distribution tax (DDT) was introduced to ease collection of... Read more

Modification of Indian Tax Residency Rules
The global movement of Indians from India to other countries has finally caught the eye of the Indian administration. India seems to be... Read more

Indian entities and U.S. taxation: U.S. partnerships
The flow through framework for partnerships in the U.S. means that the taxes are applied to partners rather than a partnership entity. It... Read more

Restructuring your US operations – Part 3: Anti-avoidance rules in the Internal Revenue Code
Where a corporate reorganization results in a transfer of property to a foreign corporation (such as an Australian registered company), the normal nonrecognition... Read more