ECI (Effectively Connected Income) and U.S.-source Income

Foreign persons pay taxes to the U.S. only on income earned in the U.S. territory. This plain statement is not that simple when applying your situations into tax laws. International tax laws, especially in inbound tax, are full of surprise. Choi & Partners help you:

  • Structuring investment in U.S. real properties
  • Planning for transactions with the foreign parent companies
  • Analyzing treaty benefits
  • Evaluating U.S. entity alternatives
  • Reporting U.S. branch or subsidiary operations
  • Compliance with the withholding requirements