Services
Inbound Tax Planning
U.S. international tax rules also affect foreign corporations doing business in the United States. These tax rules should be considered by foreign multinationals who wish to minimize U.S. tax costs in their efforts to reduce their global effective tax rates. USTA advises foreign clients on their U.S. income tax exposure, focusing on:
- Inbound structuring;
- Minimizing the risk of being considered to be engaged in a U.S. trade or business;
- The branch profits tax;
- Withholding tax;
- Conduit financing;
- Earnings stripping; and
- Tax treaty implications