Investment cross the border is not exclusive to big corporations anymore. Lots of small businesses have international exposure. FATCA and FBAR educate individuals can be international investors. Governments want to tax on income beyond the traditional tax regime. In addition, the U.S. consists of 50 states and 1 district which have different tax laws. Choi & Partners help you evaluate your tax risks and plan for better.

U.S. shareholders of CFCs may pay tax on the CFCs’ earnings even before actual distributions from the CFCs. A foreign corporation is a CFC if 50%+ stocks are owned by U.S. shareholders. The Tax Cuts and Jobs Act of 2017 added one-time transition tax and GILTI provisions. The Code and the Regulations provide various exceptions, exemptions, and elections to the taxes. The court cases and the Revenue Procedures confirm those escapes. Assess your situations, plan ahead, and avoid surprise. Choi & Partners help you:

  • Evaluating Subpart F including GILTI and other anti-deferral tax provisions
  • Maximizing Foreign tax credit
  • Repatriation planning including distribution of PTEP
  • Structuring foreign entities for better tax result
  • Planning for FDII deduction and IC-DISC incentive

U.S. persons may pay taxes more than usual if invested in PFICs. A foreign corporation is a PIFC if 75% of the corporation’s income is passive, or 50% of the corporation’s assets are held for production of passive income. Foreign private equity funds are PFICs. Foreign ETF, mutual funds, index funds could be PFICs. If proper elections neither available nor timely made, growth in PFICs may be subject to the highest rate of tax beyond the favorable qualified dividends and capital gain tax rate. Choi & Partners help you:

  • Evaluating PFIC tax risks and alternatives/li>
  • Guiding PFIC administrators to provide QEF information to investors/li>
  • Structuring PFIC to avoid unfavorable tax result

FBAR and FATCA are not special tax provisions anymore. These notorious acronyms were fear to many U.S. persons. More than million U.S. persons came forward to correct wrong-doings in the past. Hundreds of thousands of U.S. persons hiccupped with harsh penalties and imprisonments. Now is the time to understand the U.S. government’s intention and plan for the future. Choi & Partners help you:

  • Evaluating Subpart F including GILTI and other anti-deferral tax provisions
  • Maximizing Foreign tax credit
  • Repatriation planning including distribution of PTEP
  • Structuring foreign entities for better tax result
  • Planning for FDII deduction and IC-DISC incentive

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/li>
  • Planning for transactions with the foreign parent companies/li>
  • Analyzing treaty benefits/li>
  • Evaluating U.S. entity alternatives/li>
  • Reporting U.S. branch or subsidiary operations

Tax home is an essential concept in the U.S. and state tax laws. It is where you live to most of taxpayers. Mobility may shake this common definition, as are true to professional athletes and performing artists. If you are in one of these professions, you may have multiple tax homes. You may pay taxes to cities and states where you earn income. Deductions can be different from those with one tax home. Choi & Partners help you:

  • Evaluating state tax risks including Income tax, Franchise tax and Gross receipts tax
  • Analyzing income allocation rules unique to leagues and occupations
  • Structuring U.S. entities to maximize business deductions
  • Establishing and severing state residency