Discussion will include choice of entity decisions for U.S. persons engaging in business operations overseas, including the use of hybrid entities; nexus for foreign tax exposure including treaty provisions such as the permanent establishment rule, taxation of foreign source business income.
Other topics include foreign tax credit implications and limitations; anti-foreign tax credit splitting rules; withholding tax implications, transfer pricing issues and moving intangibles overseas. Mr. August will also discuss the IC-DISC rules and potential impact of Tax Reform on international business taxation.
1 Constitution Sq
New Brunswick, NJ 08901
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