
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

Indian entities and U.S. taxation – Effectively connected U.S. income
An Indian entity doing business in the U.S., unlike a U.S. incorporated entity, is generally taxable in the U.S. ‘on its taxable income... 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