News & Analysis as of

Foreign Investment Internal Revenue Service Limited Liability Company (LLC)

Tannenbaum Helpern Syracuse & Hirschtritt LLP

Establishing a Subsidiary in the U.S. - A Nordic Perspective

This note only addresses subsidiaries of Nordic companies. Branch offices are rarely attractive for foreign companies because they result in direct exposure for the foreign company to liability in the U.S. and jurisdiction by...more

Holland & Knight LLP

IRS anuncia amnistía fiscal internacional nueva hasta el 30 de septiembre de 2022

Holland & Knight LLP on

El servicio de impuestos internos de Estados Unidos (Internal Revenue Service o IRS) recientemente anunció una amnistía nueva que permite presentar ciertas declaraciones de 2019 y 2020 sin multa antes del 30 de septiembre de...more

Rosenberg Martin Greenberg LLP

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other...

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated.  Each of these has its own corresponding penalties and generally applies to United States...more

Sheppard Mullin Richter & Hampton LLP

Opening a U.S. Bank Account Can be Much More Onerous than you Think and Can Delay Your Cross-Border Transaction or Growth Plans in...

French investments in the U.S. vary largely in terms of scale and nature, but whatever it is a small French startup only creating an even smaller U.S. subsidiary or a large French corporation acquiring and restructuring an...more

Mintz

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

Mintz on

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

Alston & Bird

Big Tax Court Win for Foreign Investors in U.S. Partnerships

Alston & Bird on

A foreign investor, not engaged in a U.S. trade or business, can sell stock in a U.S. corporation without fear of U.S. tax liability (with the notable exception of stock in certain U.S. corporations heavily invested in U.S....more

Cozen O'Connor

New IRS Reporting Rule Could Bite Unwary Foreign Investors

Cozen O'Connor on

There are two main sources of reporting requirements for foreign investors in the United States — the Internal Revenue Service and the Bureau of Economic Analysis. The IRS recently upped its game by requiring reports from...more

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