Structuring Foreign Investments

Course Demo. No credit provided in demo mode.

Credit Hours:
CA - General: 1.0 Credits
NY - General: 1.0 Credits
IL - General: 1.0 Credits
AZ - General: 1.0 Credits
IN - Distance Education: 1.0 Credits
FL - General: 1.0 Credits

Running Time: 1 Hours, 1 Minutes
Faculty: Jacob Stein, Esq -

Course Description

Structuring foreign investment in the U.S. is a hot topic. With lots of money pouring into the U.S. from the BRIC countries a lot of practitioners find themselves representing foreign clients. Representing such clients requires an understanding of U.S. taxation of foreigners and choice of entity. The discussion of U.S. taxation of foreign investment in the U.S. will provide an overview of effectively connected income, FDAP withholding, FIRPTA withholding, treaty application, branch profits tax and residence tests. Particular attention will be devoted to appropriate entity structures, including onshore-offshore hybrid structures.