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  • Cross-border Tax Planning

U.S. CROSS-BORDER
tax review for
NON-US TAX PAYER

The Bridge

Operating with confidence in the world’s largest economy.

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Who is this for?

Designed for non-U.S. entrepreneurs, foreign
companies, and international investors seeking to enter the U.S. market or operate globally through U.S.
structures. This review is ideal for foreign businesses or
entrepreneurs establishing U.S. LLCs, international
businesses selling to or through the United States, and
non-U.S. investors holding US assets.

The United States imposes tax, reporting, and withholding obligations on non-U.S. businesses and investors. Operating in, selling into, or structuring through the United States without proper planning can trigger U.S. taxation and long-term banking and compliance complications.

Because U.S. tax rules are complex, aggressively enforced, and highly fact-specific, proactive inbound structuring is essential to access the U.S. market or operate through the US efficiently, and without creating hidden or irreversible tax exposure.
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Why do you need this service?

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Technical Scope

Where U.S. tax is triggered, why it is triggered, and how exposure can be managed legally and defensibly.

The U.S. tax system contains complex rules that can subject foreign persons and foreign-owned US LLCs to U.S. taxation even when no physical presence exists. This review analyzes how U.S. tax rules apply when non-U.S. persons operate in the United States or through U.S. LLCs.

The goal is to clearly identify where U.S. tax is triggered, why it is triggered, and how exposure can potentially be managed.

This review focuses on FOUR core U.S. international tax regimes:

Effectively Connected Income (ECI)

We analyze whether business activities or income streams may be treated as effectively connected with a U.S. trade or business and explain the resulting U.S. tax obligations.

FDAP Income & Withholding Tax

We review income streams to determine whether they constitute Fixed or Determinable Annual or Periodical (FDAP) income and assess applicable U.S. withholding tax exposure.

Permanent Establishment

We evaluate permanent establishment and dependent agent risks under U.S. tax law and applicable treaties, including attribution of income to U.S. offices or representatives.

U.S. Estate Tax Exposure for Non-Resident Aliens domiciled abroad

We assess potential U.S. estate tax exposure arising from U.S. assets held directly or indirectly by non-U.S. individuals.

Deliverable

A customized, personalized and bespoke document explaining to the client how to navigate the US tax landscape. The U.S. Cross-border Tax Review for U.S. persons as detailed in this section is applicable to one (1) corporate entity or one (1) trust.

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