2025 Australian Federal Budget Summary On Tuesday, March...
In our 13th installment of the Family Office...
2024 Australian Federal Budget Summary On Tuesday 14th...
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
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
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... Read more
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,... Read more