Brian attended the World Conference hosted by GGI annually. It was held in Cape Town, South Africa this year. His topic was on the tax implications of bring business from abroad to the U.S.
Daseke acquires aveda transaction presentation - april 2018irdaseke
Daseke will acquire Aveda Transportation & Energy Services, a leading oil rig moving company in North America, for $128.6 million. The acquisition will diversify Daseke's revenue stream and provide synergies from Aveda's complementary customer base and economies of scale. Aveda has a market leading position in its niche market and experienced management team. The acquisition multiple is attractive given Aveda's execution and expected synergies with Daseke.
Daseke acquires aveda transaction presentation - april 2018irdaseke
Daseke will acquire Aveda Transportation & Energy Services for approximately $101.5 million. Aveda is a leading provider of specialized transportation services for the oil and gas industry in North America. The acquisition will diversify Daseke's revenue streams and is expected to achieve synergies through economies of scale. Aveda has a blue chip customer base and experienced management team. The transaction valuation is attractive given Aveda's execution and expected synergies with Daseke.
In general terms, this is one of the most frequent questions we get from prospective clients. So then, How do you file US tax returns while in Canada?
The first question we need to ask is whether you’re actually required to file US tax returns. Generally speaking, US citizens and Green Card holders are required to file US tax returns regardless of where they live. Therefore Americans living in Canada, whether they’ve recently moved to Canada or have been in the country their entire lives are required to file US tax returns in addition to their regular Canadian tax returns.
The Home Depot Announces First Quarter Resultsfinance2
The Home Depot reported first quarter earnings of $356 million, down from $1 billion in the same period last year. This included a $543 million non-recurring charge for closing underperforming stores. Excluding this charge, earnings were $697 million. Sales decreased 3.4% to $17.9 billion due to a 6.5% drop in comparable store sales. The company's CEO acknowledged difficult market conditions and said the company would focus on investing in existing stores.
Cite Reporting The Results Of Foreign Operations Jan 2011randyfree
This document discusses reporting the results of foreign operations for US tax purposes. It covers obtaining financial and structural information from overseas affiliates, key issues in reviewing Form 5471 for foreign corporations, and computing earnings and profits to reconcile with financial statements. Challenges obtaining reliable information from foreign entities are also addressed, as are risks of mistakes on Form 5471 that could result in penalties.
International Tax Reform for US Individuals and Pass-through Entities Fenwick & West
This document summarizes a presentation by William Skinner on new tax rules under the Tax Cuts and Jobs Act that impact individual owners of controlled foreign corporations (CFCs). Key changes include the introduction of a global minimum tax called GILTI on the foreign income of CFCs, which is currently taxed at ordinary rates to US shareholders. GILTI applies to the net income of CFCs in excess of a 10% return on depreciable tangible assets. The presentation provides examples of how GILTI is calculated and discusses the impact of making an election under Section 962 to be taxed at corporate rates on GILTI income. It also notes some advantages of GILTI for US corporate shareholders,
Q4 2008 American Express Company Earnings earningsreport
- American Express reported lower Q4 2008 earnings compared to Q4 2007, with diluted EPS down 71%. Revenues declined 11% due to weaker economic conditions impacting card spending and loan balances.
- Key metrics like billed business, average spending per card, and lending balances all decreased in the double-digit percentages compared to the previous year.
- The company took restructuring and other charges totaling over $500 million after-tax in Q4 2008. It also increased reserves for credit losses and its Membership Rewards program.
- American Express became a bank holding company in November 2008 and revised its financial reporting framework. It also received $3.39 billion in funding from the Treasury's TARP
The document summarizes AmeriGas Partners' fiscal 2017 third quarter results. Weather was warmer than the prior year, lowering propane demand and volumes by 4%, though margins increased due to higher average propane costs. Adjusted EBITDA was $58.4 million compared to $64.6 million last year. Cylinder exchange and national accounts volumes grew. Guidance for full year fiscal 2017 Adjusted EBITDA remains at $550 million. Acquisitions and debt refinancing were also discussed.
Daseke acquires aveda transaction presentation - april 2018irdaseke
Daseke will acquire Aveda Transportation & Energy Services, a leading oil rig moving company in North America, for $128.6 million. The acquisition will diversify Daseke's revenue stream and provide synergies from Aveda's complementary customer base and economies of scale. Aveda has a market leading position in its niche market and experienced management team. The acquisition multiple is attractive given Aveda's execution and expected synergies with Daseke.
Daseke acquires aveda transaction presentation - april 2018irdaseke
Daseke will acquire Aveda Transportation & Energy Services for approximately $101.5 million. Aveda is a leading provider of specialized transportation services for the oil and gas industry in North America. The acquisition will diversify Daseke's revenue streams and is expected to achieve synergies through economies of scale. Aveda has a blue chip customer base and experienced management team. The transaction valuation is attractive given Aveda's execution and expected synergies with Daseke.
In general terms, this is one of the most frequent questions we get from prospective clients. So then, How do you file US tax returns while in Canada?
The first question we need to ask is whether you’re actually required to file US tax returns. Generally speaking, US citizens and Green Card holders are required to file US tax returns regardless of where they live. Therefore Americans living in Canada, whether they’ve recently moved to Canada or have been in the country their entire lives are required to file US tax returns in addition to their regular Canadian tax returns.
The Home Depot Announces First Quarter Resultsfinance2
The Home Depot reported first quarter earnings of $356 million, down from $1 billion in the same period last year. This included a $543 million non-recurring charge for closing underperforming stores. Excluding this charge, earnings were $697 million. Sales decreased 3.4% to $17.9 billion due to a 6.5% drop in comparable store sales. The company's CEO acknowledged difficult market conditions and said the company would focus on investing in existing stores.
Cite Reporting The Results Of Foreign Operations Jan 2011randyfree
This document discusses reporting the results of foreign operations for US tax purposes. It covers obtaining financial and structural information from overseas affiliates, key issues in reviewing Form 5471 for foreign corporations, and computing earnings and profits to reconcile with financial statements. Challenges obtaining reliable information from foreign entities are also addressed, as are risks of mistakes on Form 5471 that could result in penalties.
International Tax Reform for US Individuals and Pass-through Entities Fenwick & West
This document summarizes a presentation by William Skinner on new tax rules under the Tax Cuts and Jobs Act that impact individual owners of controlled foreign corporations (CFCs). Key changes include the introduction of a global minimum tax called GILTI on the foreign income of CFCs, which is currently taxed at ordinary rates to US shareholders. GILTI applies to the net income of CFCs in excess of a 10% return on depreciable tangible assets. The presentation provides examples of how GILTI is calculated and discusses the impact of making an election under Section 962 to be taxed at corporate rates on GILTI income. It also notes some advantages of GILTI for US corporate shareholders,
Q4 2008 American Express Company Earnings earningsreport
- American Express reported lower Q4 2008 earnings compared to Q4 2007, with diluted EPS down 71%. Revenues declined 11% due to weaker economic conditions impacting card spending and loan balances.
- Key metrics like billed business, average spending per card, and lending balances all decreased in the double-digit percentages compared to the previous year.
- The company took restructuring and other charges totaling over $500 million after-tax in Q4 2008. It also increased reserves for credit losses and its Membership Rewards program.
- American Express became a bank holding company in November 2008 and revised its financial reporting framework. It also received $3.39 billion in funding from the Treasury's TARP
The document summarizes AmeriGas Partners' fiscal 2017 third quarter results. Weather was warmer than the prior year, lowering propane demand and volumes by 4%, though margins increased due to higher average propane costs. Adjusted EBITDA was $58.4 million compared to $64.6 million last year. Cylinder exchange and national accounts volumes grew. Guidance for full year fiscal 2017 Adjusted EBITDA remains at $550 million. Acquisitions and debt refinancing were also discussed.
Iron Mountain reported financial results for the fourth quarter and full year of 2015. While total reported revenues declined slightly due to currency impacts, constant currency total revenue growth was 2.1% for both the quarter and full year, in line with guidance. Adjusted OIBDA for the quarter and full year met or exceeded expectations. The company achieved its service gross margin target for the quarter and realized $50 million in annualized savings from its ongoing Transformation initiative. Iron Mountain reiterated its 2016 constant currency revenue growth guidance provided previously.
Iron Mountain reported financial results for the fourth quarter and full year of 2015. While total reported revenues declined year-over-year due to currency impacts, constant currency total revenue growth was 2.1% for both the quarter and full year, driven by storage rental revenue gains. Adjusted OIBDA increased 13.6% for the quarter and 4.4% for the full year on a constant currency basis. The company executed on its transformation initiative and achieved its service gross margin target for the quarter. Iron Mountain provided guidance for 2016 that is in line with expectations set at its investor day.
Aubrey Batzinger has over 6 years of experience in taxation. She currently works as a Tax Associate II - Six Sigma Specialist at Raytheon in Waltham, MA where she researches international tax opportunities, provides tax analysis and guidance on international contracts, and manages processes related to tax calculations and forms. Previously, she worked as a Tax Associate at Raytheon where she prepared state tax returns and completed a Six Sigma project. She also has experience preparing tax returns as a Tax Assistant at Jeffrey Morgen C.P.A. Firm.
The second quarter results presentation covered AmeriGas's performance in the fiscal year 2017 second quarter. Key points included:
- The quarter was warmer than normal and last year, leading to a 6% decline in retail propane volume sold. However, unit margins increased 2% despite higher propane costs.
- Adjusted EBITDA was $271.2 million, down 8% from the prior year second quarter.
- Growth initiatives such as cylinder exchange and national accounts saw increased volume, and the company expects to complete 3 acquisitions in the coming months.
- AmeriGas refinanced its long term debt, reducing interest rates and extending maturities with no significant debt due until 2024.
This document provides an overview of Owens Corning's performance in Q1 2017 across three investor presentations. It discusses the company's focus on shareholder value and forward-looking statements. The company has three strong businesses - Insulation, Roofing, and Composites - with balanced end market exposure. It highlights the investment thesis in Owens Corning including market leading businesses, improved portfolio, earnings, and cash flow, and attractive macroeconomic drivers. Additional financial information is also presented on the individual businesses and their historical performance.
- Eco-Stim Energy Solutions provides well stimulation and other oilfield services using natural gas powered equipment.
- The company has three well stimulation spreads across the US and Argentina with a total capacity of around 164,000 HHP.
- Recent developments include commencing work with the second US spread in October 2017, negotiating an early contract release for the first US spread to transition to more profitable work, and implementing changes to the Argentina contract starting in February 2018 to improve profitability.
Iron Mountain reported second quarter 2014 financial results, with total revenues of $787 million, up 4.3% year-over-year on a constant currency basis. Adjusted OIBDA was $242 million, up 4.1% year-over-year. Adjusted EPS was $0.41 per share. The company continued progress on its strategic plan through acquisitions in emerging and developed markets totaling $72 million. Iron Mountain also owns more of its strategic real estate, completing its first above-ground data center.
DuPont reported first quarter 2017 earnings. Operating earnings per share increased 30% compared to the first quarter of 2016, driven by improved volume, local price benefits and cost savings. Global sales increased 5% overall with growth in all regions except the U.S. and Canada. Segment operating earnings increased 16% compared to the prior year.
weyerhaeuser Citigroup 11th Annual Global Paper and Forest Products Conferenc...finance15
This document summarizes a Citigroup conference call with Dick Taggart, CFO of Weyerhaeuser, and Patty Bedient, SVP of Finance. Taggart discussed Weyerhaeuser's strategies to improve business segment performance and invest for growth. He also outlined steps to return value to shareholders, including dividend increases and share repurchases. Bedient provided an overview of the pending transaction to merge Weyerhaeuser fine paper assets with Domtar, creating a North American leader in uncoated freesheet paper. Taggart concluded with comments on maintaining the company's target capital structure amid the current housing cycle.
The document provides a summary of Fannie Mae's 2004 Annual Report on SEC Form 10-K, which was restated. Some key points:
- The restatement resulted in a $6.3 billion total reduction in retained earnings through June 30, 2004 due to accounting errors.
- Net income in 2002 decreased $705 million due to the restatement but increased $176 million in 2003.
- Stockholders' equity increased $4.1 billion through June 30, 2004 despite a decrease in retained earnings.
- The estimated fair value of net assets increased $11.7 billion from 2003 to 2004, driven partly by a $5 billion preferred stock offering.
This document provides an overview of RioCan's third quarter 2016 results and financial position:
- Funds from operations increased year-over-year driven by growth in net operating income. Occupancy rates also improved across the portfolio.
- RioCan acquired over $1.2 billion in properties in Canada since last year and completed a debenture offering at a historically low interest rate.
- Financial metrics like interest coverage and leverage remain conservative and RioCan maintains a staggered debt maturity schedule with low floating rate exposure.
Daseke is presenting an investor presentation on consolidating the flatbed and specialized logistics market in North America. The presentation highlights Daseke's opportunity for growth through acquisitions, improved industry fundamentals, proven M&A track record, and management's alignment of interests. Key metrics provided include pro forma 2016 revenue of $818 million and Adjusted EBITDA of $108 million, with targets of $979 million in revenue and $140 million in Adjusted EBITDA for 2017.
Daseke reported financial results for Q2 2017, with revenue increasing 15.8% over Q2 2016 to $197.3 million. Both the Specialized and Flatbed segments saw revenue and Adjusted EBITDA growth compared to Q2 2016 and Q1 2017. Rates per mile and revenue per truck increased in both segments from Q1 2017 to Q2 2017. Daseke reaffirmed its 2017 pro forma Adjusted EBITDA target of $140 million. Recent acquisitions contributed $19.4 million in revenue for Q2 2017.
Daniel Lawn has over 30 years of experience in tax and accounting roles. He received a B.S. in Accounting from Salem State College in 1997. Most recently, he worked as a Senior Tax Analyst at Plymouth Rock Assurance Corporation from 2006 to 2014, where he prepared and filed over 20 federal and state tax returns. Prior to that, he held senior tax roles at Varian Semiconductor and The Forum Company, where he managed tax return preparation, estimated payments, and was the company representative for various audits.
This document provides highlights from Aimia's Q1 2017 results, including forward-looking statements about certain financial metrics for 2017. Such statements involve assumptions and are subject to risks and uncertainties that could cause actual results to differ materially. It also contains non-GAAP financial measures and reconciliations to GAAP measures. The document cautions that the assumptions used to make forward-looking statements about 2017 may prove incorrect or inaccurate.
May 2 2018 q earnings 05012018 compressed v2molsoncoorsir
Molson Coors reported lower net sales and underlying EBITDA in Q1 2018 compared to Q1 2017. The results were impacted by distributor inventory destocking in the US, overall softness in the US beer industry, and cycling a prior year tax benefit in Europe. Guidance for 2018 remains unchanged, including targets for cost savings and free cash flow. The presentation focuses on growing brands across segments, driving premiumization, and realizing further synergies and cost efficiencies.
- MGM Resorts reported second quarter 2017 earnings, with diluted EPS of $0.36 including benefits from a property tax settlement and modification to exit fees. Net income was $211 million.
- Consolidated net revenue increased 16% year-over-year to $2.6 billion, with domestic resorts revenue up 22% to $2.1 billion. Same-store net revenue decreased 1% largely due to lower table games hold.
- RevPAR at Las Vegas Strip resorts increased 1.2% to $151. Consolidated Adjusted Property EBITDA was $824 million, with domestic resorts EBITDA up 28% to $658 million including contributions from Borgata and
The document provides information on Molson Coors' 4th quarter and full year 2017 earnings. It discusses forward-looking statements and non-GAAP information. It then discusses Molson Coors' focus on delivering growth and shareholder value through earning more, using less, and investing wisely. The document summarizes Molson Coors' consolidated 4th quarter and full year 2017 performance, noting solid top and bottom line growth. It then provides more detailed summaries of Molson Coors' performance in key regions - the United States, Canada, and Europe - noting trends in volumes, pricing, and earnings for both the 4th quarter and full year of 2017.
Daseke reported Q1 2017 financial results consistent with expectations. Total revenue increased 2.2% compared to Q1 2016 due to driving more miles, though additional operating costs from new leases and higher fuel costs slightly reduced efficiency. The company continues executing its consolidation strategy in the open deck specialized transportation market through acquisitions. An improving industry environment is also noted.
This document summarizes two major state tax issues for architecture and engineering (A&E) firms: sales/use tax and state income tax. It discusses how A&E services are defined for tax purposes and whether they are taxable. It also addresses nexus, voluntary disclosure agreements, registering in other states, and tax compliance issues when working in multiple states. The presentation aims to help A&E firms evaluate their tax exposure and compliance across different states.
Peter and Harriet were invited to speak at an event hosted by Dentons law firm for Belgium investors interested in expanding their business on U.S. soil.
10 faq for foreign companies establishing operations in the united statesEliot Norman
THese Frequently asked questions (FAQ) cover corporate formation, protection of Intellectual property, contracts, visas, taxes and more. A checklist of what you need to consider before setting up a company in the USA.
Iron Mountain reported financial results for the fourth quarter and full year of 2015. While total reported revenues declined slightly due to currency impacts, constant currency total revenue growth was 2.1% for both the quarter and full year, in line with guidance. Adjusted OIBDA for the quarter and full year met or exceeded expectations. The company achieved its service gross margin target for the quarter and realized $50 million in annualized savings from its ongoing Transformation initiative. Iron Mountain reiterated its 2016 constant currency revenue growth guidance provided previously.
Iron Mountain reported financial results for the fourth quarter and full year of 2015. While total reported revenues declined year-over-year due to currency impacts, constant currency total revenue growth was 2.1% for both the quarter and full year, driven by storage rental revenue gains. Adjusted OIBDA increased 13.6% for the quarter and 4.4% for the full year on a constant currency basis. The company executed on its transformation initiative and achieved its service gross margin target for the quarter. Iron Mountain provided guidance for 2016 that is in line with expectations set at its investor day.
Aubrey Batzinger has over 6 years of experience in taxation. She currently works as a Tax Associate II - Six Sigma Specialist at Raytheon in Waltham, MA where she researches international tax opportunities, provides tax analysis and guidance on international contracts, and manages processes related to tax calculations and forms. Previously, she worked as a Tax Associate at Raytheon where she prepared state tax returns and completed a Six Sigma project. She also has experience preparing tax returns as a Tax Assistant at Jeffrey Morgen C.P.A. Firm.
The second quarter results presentation covered AmeriGas's performance in the fiscal year 2017 second quarter. Key points included:
- The quarter was warmer than normal and last year, leading to a 6% decline in retail propane volume sold. However, unit margins increased 2% despite higher propane costs.
- Adjusted EBITDA was $271.2 million, down 8% from the prior year second quarter.
- Growth initiatives such as cylinder exchange and national accounts saw increased volume, and the company expects to complete 3 acquisitions in the coming months.
- AmeriGas refinanced its long term debt, reducing interest rates and extending maturities with no significant debt due until 2024.
This document provides an overview of Owens Corning's performance in Q1 2017 across three investor presentations. It discusses the company's focus on shareholder value and forward-looking statements. The company has three strong businesses - Insulation, Roofing, and Composites - with balanced end market exposure. It highlights the investment thesis in Owens Corning including market leading businesses, improved portfolio, earnings, and cash flow, and attractive macroeconomic drivers. Additional financial information is also presented on the individual businesses and their historical performance.
- Eco-Stim Energy Solutions provides well stimulation and other oilfield services using natural gas powered equipment.
- The company has three well stimulation spreads across the US and Argentina with a total capacity of around 164,000 HHP.
- Recent developments include commencing work with the second US spread in October 2017, negotiating an early contract release for the first US spread to transition to more profitable work, and implementing changes to the Argentina contract starting in February 2018 to improve profitability.
Iron Mountain reported second quarter 2014 financial results, with total revenues of $787 million, up 4.3% year-over-year on a constant currency basis. Adjusted OIBDA was $242 million, up 4.1% year-over-year. Adjusted EPS was $0.41 per share. The company continued progress on its strategic plan through acquisitions in emerging and developed markets totaling $72 million. Iron Mountain also owns more of its strategic real estate, completing its first above-ground data center.
DuPont reported first quarter 2017 earnings. Operating earnings per share increased 30% compared to the first quarter of 2016, driven by improved volume, local price benefits and cost savings. Global sales increased 5% overall with growth in all regions except the U.S. and Canada. Segment operating earnings increased 16% compared to the prior year.
weyerhaeuser Citigroup 11th Annual Global Paper and Forest Products Conferenc...finance15
This document summarizes a Citigroup conference call with Dick Taggart, CFO of Weyerhaeuser, and Patty Bedient, SVP of Finance. Taggart discussed Weyerhaeuser's strategies to improve business segment performance and invest for growth. He also outlined steps to return value to shareholders, including dividend increases and share repurchases. Bedient provided an overview of the pending transaction to merge Weyerhaeuser fine paper assets with Domtar, creating a North American leader in uncoated freesheet paper. Taggart concluded with comments on maintaining the company's target capital structure amid the current housing cycle.
The document provides a summary of Fannie Mae's 2004 Annual Report on SEC Form 10-K, which was restated. Some key points:
- The restatement resulted in a $6.3 billion total reduction in retained earnings through June 30, 2004 due to accounting errors.
- Net income in 2002 decreased $705 million due to the restatement but increased $176 million in 2003.
- Stockholders' equity increased $4.1 billion through June 30, 2004 despite a decrease in retained earnings.
- The estimated fair value of net assets increased $11.7 billion from 2003 to 2004, driven partly by a $5 billion preferred stock offering.
This document provides an overview of RioCan's third quarter 2016 results and financial position:
- Funds from operations increased year-over-year driven by growth in net operating income. Occupancy rates also improved across the portfolio.
- RioCan acquired over $1.2 billion in properties in Canada since last year and completed a debenture offering at a historically low interest rate.
- Financial metrics like interest coverage and leverage remain conservative and RioCan maintains a staggered debt maturity schedule with low floating rate exposure.
Daseke is presenting an investor presentation on consolidating the flatbed and specialized logistics market in North America. The presentation highlights Daseke's opportunity for growth through acquisitions, improved industry fundamentals, proven M&A track record, and management's alignment of interests. Key metrics provided include pro forma 2016 revenue of $818 million and Adjusted EBITDA of $108 million, with targets of $979 million in revenue and $140 million in Adjusted EBITDA for 2017.
Daseke reported financial results for Q2 2017, with revenue increasing 15.8% over Q2 2016 to $197.3 million. Both the Specialized and Flatbed segments saw revenue and Adjusted EBITDA growth compared to Q2 2016 and Q1 2017. Rates per mile and revenue per truck increased in both segments from Q1 2017 to Q2 2017. Daseke reaffirmed its 2017 pro forma Adjusted EBITDA target of $140 million. Recent acquisitions contributed $19.4 million in revenue for Q2 2017.
Daniel Lawn has over 30 years of experience in tax and accounting roles. He received a B.S. in Accounting from Salem State College in 1997. Most recently, he worked as a Senior Tax Analyst at Plymouth Rock Assurance Corporation from 2006 to 2014, where he prepared and filed over 20 federal and state tax returns. Prior to that, he held senior tax roles at Varian Semiconductor and The Forum Company, where he managed tax return preparation, estimated payments, and was the company representative for various audits.
This document provides highlights from Aimia's Q1 2017 results, including forward-looking statements about certain financial metrics for 2017. Such statements involve assumptions and are subject to risks and uncertainties that could cause actual results to differ materially. It also contains non-GAAP financial measures and reconciliations to GAAP measures. The document cautions that the assumptions used to make forward-looking statements about 2017 may prove incorrect or inaccurate.
May 2 2018 q earnings 05012018 compressed v2molsoncoorsir
Molson Coors reported lower net sales and underlying EBITDA in Q1 2018 compared to Q1 2017. The results were impacted by distributor inventory destocking in the US, overall softness in the US beer industry, and cycling a prior year tax benefit in Europe. Guidance for 2018 remains unchanged, including targets for cost savings and free cash flow. The presentation focuses on growing brands across segments, driving premiumization, and realizing further synergies and cost efficiencies.
- MGM Resorts reported second quarter 2017 earnings, with diluted EPS of $0.36 including benefits from a property tax settlement and modification to exit fees. Net income was $211 million.
- Consolidated net revenue increased 16% year-over-year to $2.6 billion, with domestic resorts revenue up 22% to $2.1 billion. Same-store net revenue decreased 1% largely due to lower table games hold.
- RevPAR at Las Vegas Strip resorts increased 1.2% to $151. Consolidated Adjusted Property EBITDA was $824 million, with domestic resorts EBITDA up 28% to $658 million including contributions from Borgata and
The document provides information on Molson Coors' 4th quarter and full year 2017 earnings. It discusses forward-looking statements and non-GAAP information. It then discusses Molson Coors' focus on delivering growth and shareholder value through earning more, using less, and investing wisely. The document summarizes Molson Coors' consolidated 4th quarter and full year 2017 performance, noting solid top and bottom line growth. It then provides more detailed summaries of Molson Coors' performance in key regions - the United States, Canada, and Europe - noting trends in volumes, pricing, and earnings for both the 4th quarter and full year of 2017.
Daseke reported Q1 2017 financial results consistent with expectations. Total revenue increased 2.2% compared to Q1 2016 due to driving more miles, though additional operating costs from new leases and higher fuel costs slightly reduced efficiency. The company continues executing its consolidation strategy in the open deck specialized transportation market through acquisitions. An improving industry environment is also noted.
This document summarizes two major state tax issues for architecture and engineering (A&E) firms: sales/use tax and state income tax. It discusses how A&E services are defined for tax purposes and whether they are taxable. It also addresses nexus, voluntary disclosure agreements, registering in other states, and tax compliance issues when working in multiple states. The presentation aims to help A&E firms evaluate their tax exposure and compliance across different states.
Peter and Harriet were invited to speak at an event hosted by Dentons law firm for Belgium investors interested in expanding their business on U.S. soil.
10 faq for foreign companies establishing operations in the united statesEliot Norman
THese Frequently asked questions (FAQ) cover corporate formation, protection of Intellectual property, contracts, visas, taxes and more. A checklist of what you need to consider before setting up a company in the USA.
Setting up a company in the USA as a Non-Resident (IT Industry)Smart Accountants
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our webinar series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
The document discusses various tax planning and compliance topics including:
- Debt vs. equity classification and its tax implications
- Delaware franchise tax calculation methods
- State tax implications of establishing US operations
- Sales tax issues and audits
- Use of Form W-8 for foreign entities
It provides an overview of these issues and considerations for proper tax planning and compliance, especially important for tax audits.
The document discusses tax planning and compliance strategies for businesses operating in the United States. It covers topics such as debt versus equity classification, Delaware franchise taxes, establishing US operations and related state tax implications, sales tax issues and audits, and IRS Form W-8 requirements for foreign entities. An agenda is provided outlining these issues to ensure proper tax planning and compliance to prepare for potential tax audits.
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our PPT series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
Les 10 FAQ: S'Implanter aux Etats-Unis Eliot Norman
un guide pratique aux questions les plus frequemment posee sur les implantations aux Etats-Unis: visas, contrats, incorporation, PI, impots, droit social.
Everything your startup needs to know about accountingThe Idea Village
Don't get lost in the accounting world as you steer your venture to success! In this IDEAinstitute, attendees will be guided by the accounting startup compass: tools and insights of the trade necessary to reach your venture's destination.
Doing Business in Canada - What you Need to KnowWelch LLP
Are you based in another country and thinking about expanding your business into Canada? Looking to understand the legal & tax related issues? On Tuesday, February 25th, 2014, highly experienced professionals Mona Tessier, Don Scott, & Jamie Hollingworth provided 60 minutes of detailed advice for how to conduct business in Canada.
To view this Welch LLP webinar (and others), click here: http://www.welchllp.com/resource-centre/videos/webinars/
Gerardo Diaz presents a management report for Gemstar Productions using data from Quickbooks. The report includes a balance sheet showing $50,700 in cash, $1,333 in supply inventory, and $42,153 in total liabilities. It also includes a profit and loss statement showing $11,400 in event revenue and $4,833 in net income, as well as budgets versus actuals and statements of cash flows. Gerardo also discusses internal controls like bank reconciliations and approval processes, and defines accounting concepts like accounts receivable, the balance sheet equation, and gross margin.
Succeed from the start, your guide to bringing your business to the U.S.Global Delaware
Learn the steps of opening your U.S. branch office from beginning to end - how to incorporate, navigate Federal and State requirements, taxes, visas and hiring local employees. Brought to you by the Global Delaware Concierge Team for International Business.
Succeed from the start, your guide to bringing your business to the U.S.Emma Cowdery
Learn the steps of opening a business in the U.S. from beginning to end. Brought to you by the Delaware Concierge Team for International Business, this guide outlines the necessary components of setting up your U.S. branch office from incorporating, taxes, visas, hiring employees and more. Read success stories of other international firms and get connected with experts that will help you.
This document discusses various tax strategies and considerations for a US business expanding globally. It begins with an introduction to international tax concepts and a case study. It then addresses potential risks and opportunities when exporting, selling through an agent, having employees abroad, and establishing a foreign entity. Key points include understanding delivery terms, importers of record, and tax treaty implications when exporting, properly structuring agent relationships, complying with foreign payroll and labor laws for employees abroad, and seeking both US and foreign tax advice when setting up a foreign entity.
- The document appears to be a resume for Kathryn C. Shealy, CPA, who has over 25 years of experience in tax accounting, including experience preparing tax returns, managing tax compliance, and working as a corporate tax manager and controller. She has extensive experience with federal, state, and local tax filings and tax software. She is seeking a position utilizing her tax and accounting expertise.
Doing Business in the USA is the essential conference for Founders, CEOs and C-level executives from around the world who are planning to enter or expand their business in North America.
Set on the first day of SXSW Interactive, it provides a comprehensive view of industry trends, investment, legal, tax and regional opportunities with a mix of expert speakers, case studies and candid Q&As.
For more information on the Doing Business in the USA event including the full speaker line-up check out:
http://chinwag.com/events/2013/03/sxsw-chinwag-present-doing-business-usa
The document discusses different types of business entities including sole proprietorships, C-corporations, S-corporations, partnerships, and limited liability companies. It provides an overview of the legal and tax considerations for each entity type, such as formation requirements, tax treatment, advantages, and disadvantages. The document also includes examples analyzing reasonable compensation and partnership tax issues.
Dwanah Sumo Dwanah has over 8 years of experience in federal, state, and local tax compliance and planning with major corporate tax departments. She has a Masters in Taxation and experience preparing tax returns, estimated payments, and addressing notices for many states. Dwanah also assists with tax provisions, audits, process improvements, and tax software. She is proficient in Microsoft Office, tax research tools, and ERP systems.
Dimpy Gulati founded Taxbiz Consulting, a full service tax and accounting firm based in Illinois. She has extensive experience in tax and accounting in both the US and India. Taxbiz Consulting provides services related to bookkeeping, payroll, tax return preparation, incorporation, and sales tax to both individuals and businesses. Their goal is to become the preferred tax and accounting firm in the Chicagoland area by building long-lasting client relationships.
Current Tax Planning Techniques in U.S. and International TransactionsWinston & Strawn LLP
The document summarizes various tax planning techniques for U.S. and international transactions, including:
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As an alumni to the courses taught by Professor Alan Cerf at UC Berkeley, Brian Rowbotham and Cindy Hsieh returns to campus each semester to be a guest lecturer for the new classes.
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This document provides information on cross-border tax and estate planning solutions for Chinese clients investing or doing business in the United States. It discusses typical structures like using foreign corporations and trusts to hold US and foreign assets. It also covers topics such as US tax residence rules, foreign reporting requirements, expatriation tax, and the EB-5 immigrant investor program.
U.S. Commercial Property Ownership Structures for Foreign Investors Tax, Lega...Rowbotham & Company LLP
1. There are several structures for foreign investors to own US commercial property, including direct ownership, LLCs, LPs, and foreign or domestic corporations. Key considerations include income tax rates, capital gains tax rates, and estate tax implications.
2. For multiple property investments, a US holding company structure is generally preferred to allow income and loss netting across properties while limiting liability.
3. For US residents like John and Jane, holding property in a US LLC or partnership is better than a corporation to avoid double taxation, with separate entities preferred for each property to segregate liability.
This document discusses various structures for foreign investment in U.S. real estate to minimize taxes, including owning property through a U.S. corporation or non-U.S. corporation, partnerships, and transferring properties between family members. It provides examples of different ownership structures and compares individual and corporate tax rates on income and capital gains.
This document summarizes tax planning considerations for Chinese nationals relocating to the United States for EB-5 investment or executive positions. It discusses how to determine US tax residency status, income tax rates and treaty planning. Pre-arrival planning tips are provided like realizing income before arriving, undertaking transactions to step up the basis of assets, and establishing foreign trusts or gifting assets. Reporting requirements for non-US investment entities are also summarized.
This document provides an overview of estate planning considerations for individuals with cross-border implications. It discusses U.S. gift and estate tax rules for U.S. citizens and residents as well as non-residents. It also covers generation-skipping transfer tax, pre-immigration planning, planning for permanent non-residents, and departure tax rules for expatriates. Special trusts and foreign holding entities are recommended for managing cross-border tax and asset protection issues.
The document summarizes international tax planning opportunities for individuals moving to or from the United States. It discusses pre-arrival planning strategies like realizing income, undertaking asset transactions, and establishing foreign trusts before becoming a US tax resident. It also covers US taxation of residents and nonresidents, US reporting requirements for foreign accounts/entities, and estate planning techniques.
Rowbotham & Company is a full-service CPA firm with offices in San Francisco and Silicon Valley. The firm provides audit, accounting, and domestic and international tax services to individuals and businesses. The document outlines key tax changes under the new tax act and answers international tax questions, including reporting requirements for foreign accounts and trusts. It also discusses strategies for expatriation and estate/gift tax planning.
Storytelling is an incredibly valuable tool to share data and information. To get the most impact from stories there are a number of key ingredients. These are based on science and human nature. Using these elements in a story you can deliver information impactfully, ensure action and drive change.
Navigating the world of forex trading can be challenging, especially for beginners. To help you make an informed decision, we have comprehensively compared the best forex brokers in India for 2024. This article, reviewed by Top Forex Brokers Review, will cover featured award winners, the best forex brokers, featured offers, the best copy trading platforms, the best forex brokers for beginners, the best MetaTrader brokers, and recently updated reviews. We will focus on FP Markets, Black Bull, EightCap, IC Markets, and Octa.
LA HUG - Video Testimonials with Chynna Morgan - June 2024Lital Barkan
Have you ever heard that user-generated content or video testimonials can take your brand to the next level? We will explore how you can effectively use video testimonials to leverage and boost your sales, content strategy, and increase your CRM data.🤯
We will dig deeper into:
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Structural Design Process: Step-by-Step Guide for BuildingsChandresh Chudasama
The structural design process is explained: Follow our step-by-step guide to understand building design intricacies and ensure structural integrity. Learn how to build wonderful buildings with the help of our detailed information. Learn how to create structures with durability and reliability and also gain insights on ways of managing structures.
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Recruiting in the Digital Age: A Social Media MasterclassLuanWise
In this masterclass, presented at the Global HR Summit on 5th June 2024, Luan Wise explored the essential features of social media platforms that support talent acquisition, including LinkedIn, Facebook, Instagram, X (formerly Twitter) and TikTok.
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Building Your Employer Brand with Social MediaLuanWise
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In this keynote, Luan Wise will provide invaluable insights to elevate your employer brand on social media platforms including LinkedIn, Facebook, Instagram, X (formerly Twitter) and TikTok. You'll learn how compelling content can authentically showcase your company culture, values, and employee experiences to support your talent acquisition and retention objectives. Additionally, you'll understand the power of employee advocacy to amplify reach and engagement – helping to position your organization as an employer of choice in today's competitive talent landscape.
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Part 2 Deep Dive: Navigating the 2024 Slowdownjeffkluth1
Introduction
The global retail industry has weathered numerous storms, with the financial crisis of 2008 serving as a poignant reminder of the sector's resilience and adaptability. However, as we navigate the complex landscape of 2024, retailers face a unique set of challenges that demand innovative strategies and a fundamental shift in mindset. This white paper contrasts the impact of the 2008 recession on the retail sector with the current headwinds retailers are grappling with, while offering a comprehensive roadmap for success in this new paradigm.
2. Table of Contents
Flipping into U.S. Structure
Federal Corporate Tax Rates
Foreign Corporation – Permanent Establishment
Foreign Branch
Limited Liability Company
Partnership (U.S. or Foreign)
Hybrid Structure
Delaware Corporation (Fast, Cheap, Simple & Mainstream)
State Taxes
Executive Transfers to U.S.
Example of U.S. Payroll
Appendix
Start Up Checklist for New Businesses in the U.S.
Pre-Arrival Tax Planning Checklist for Executives
Speakers Bio
2
3
4
5
6
7
8
9
10
11
12
14
25
27
3. 2
Flipping into U.S. Structure
• Raising Funds
• Going IPO in U.S.
• Tax-free Entry
• Complex to Unwind
U.S. Inc.
Foreign
Company
Other Subs.
Foreign
Company
U.S. Inc. Other Subs.
Delaware Inc.
New Investors
4. 3
For regular income tax purposes, a system of graduated marginal tax rates
is applied to all taxable income, including capital gains
Federal Corporate Tax Rates
Taxable Income ($) Tax Rate
0 to 50,000 15%
50,000 to 75,000 $7,500 + 25% Of the amount over 50,000
75,000 to 100,000 $13,750 + 34% Of the amount over 75,000
100,000 to 335,000 $22,250 + 39% Of the amount over 100,000
335,000 to 10,000,000 $113,900 + 34% Of the amount over 335,000
10,000,000 to 15,000,000 $3,400,000 + 35% Of the amount over 10,000,000
15,000,000 to 18,333,333 $5,150,000 + 38% Of the amount over 15,000,000
18,333,333 and up 35%
This rate structure produces a flat 34% tax rate on incomes from $335,000 to $10,000,000, gradually increasing
to a flat rate of 35% on incomes above $18,333,333.
5. 4
1. Foreign Parent Objective: Avoid “PE” status
U.S. company will be subjected to U.S. tax if there is:
2. Protective tax return to be filed.
Foreign Corporation – Permanent Establishment
• a place of management;
• a branch;
• an office;
• a factory;
• a workshop;
• a mine, an oil or gas well, a quarry, or any other place
of extraction of natural resources;
• Agent that habitually contracts (while in the U.S.) on behalf of
foreign company.
6. 5
• One Shareholder
• One Director
• Officers President, Treasurer, Secretary
• Common Stock
• Timing: One Day – On Line
• Can Qualify in All Other States
• Caution: Easy to Enter, Complicated with Tax Risks to Unwind.
Delaware Corporation (Fast, Cheap, Simple & Mainstream)
7. 6
Partnership (U.S. or Foreign)
U.S. Activities
(1) Foreign Owner Considerations
(2) Impact of Partnership
(3) Withholding required by partnership on U.S. source income
• Presence in U.S.
• Tax Treaty Considerations – Same as Before (Permanent Establishment)
• Does It Create U.S. Permanent Establishment?
Partnership
Foreign or U.S. OwnersForeign Owner
8. 7
Foreign Branch
Foreign Corporation
Foreign Owner
Employees and U.S. Activities
• Federal Tax Rates
• State Tax Rates
• Potential Branch Profits Tax
(1) Business Activities Taxed in U.S
(2) Branch Profits Tax
(3) Complicated Allocations of Income and Expense
• Activities that Create U.S. Tax Nexus
• Income Tax Treaty – Article 4
• Residency
• Permanent Establishment
9. 8
Limited Liability Company
Foreign Corporation
U.S. Activities
(1) Business Activities Taxed in U.S
(2) Branch Profits Tax
(3) Complicated Allocations of Income and Expense
• Activities that Create U.S. Tax Nexus
• Income Tax Treaty – Article 4
• Residency
• Permanent Establishment
LLC
11. 10
State Taxes
• Corporations are formed under state law
• State Tax Rates
U.S. Activities
Delaware California-0- Tax or
CA NY FL
8.9% 12% -0-
CA NY FL
8.9% 12% -0-
U.S. Inc.
Foreign Owner
• Most corporations are formed in Delaware, and then register to do business
in the various states where business activities are conducted.
12. 11
Immigration
• L-1 Visa
• E Visas
• H1-B Visas
• O Visa
• EB5
• Green Card
Executive Transfers to U.S.
Tax Residence
• Substantial Presence
• Legal Permanent Resident
• U.S. Citizenship
13. 12
Example of U.S. Payroll
Employee Relocation
L-1 transferee, or H1-B or E-2 Employee
$10,000 Gross Monthly Payroll [San Francisco]
Gross Pay $10,000
Withholding
Federal income tax 2,000
State income tax 700
Social security tax (1) 855
$3,575
Net pay $6,445
Federal and state
Withholding tables based on number of dependents
Form W-4 completed by employee
- 8.55% on gross wages up to $117,000 base amount
- 2.35% on wages over base amount
(1) Employer pays equal amount of social security taxes
15. 14
Start Up Checklist for New Businesses in the U.S.
Subsidiaries or Branches of Foreign Corporations
Corporations
Partnerships
Trusts
Page
2. Information Requested
3. Business Formation
4. Employee Matters
5. Foreign Companies Expanding Into The U.S.
6. Foreign Investment In U.S. Real Property
7. Tax Filings – Domestic
8. Tax Filings – International
9. Pre-Arrival Checklist
16. 15
Start Up Checklist for New Businesses in the U.S.
1. Information Requested
____________ Federal Tax Identification Number
____________ Articles of Incorporation
____________ Partnership Agreements
____________ Trust Documents
____________ Business Plan
____________ Prior Two Years Federal and State Tax Returns
____________ Cap Table
____________ Financial Statements [Audited or Unaudited]
____________ List of Current Officers
Current Information
_________________________________________ Name
_________________________________________ Address for Correspondence
_________________________________________
_________________________________________ Business Phone
_________________________________________ Mobile Phone
_________________________________________ Other Phone
_________________________________________ Correspondence Sent To
_________________________________________
_________________________________________ Name of Attorney
__________________________________________ Name of Banker
__________________________________________ Rowbotham & Company Contact
Services Requested
__________________________________________ Accounting
__________________________________________ Tax
__________________________________________ Consulting
17. 16
Start Up Checklist for New Businesses in the U.S.
2. Business Formation: To Review
____________ Business Plan
____________ Founders Names
____________ Capital/Cap Table
____________ Debt vs. Equity Structure
____________ EIN Number
____________ U.S. Bank Accounts
____________ U.S. Credit Cards
____________ Local Permits
____________ Local Payroll Taxes
____________ Board Restitutions
____________ Partnership Agreement
____________ Records – Maintenance
____________ Nexus of Company
____________ In-State Or Multi-State Activities
____________ Delaware vs. CA Corporations
____________ IP Matters [Trademarks, Patents, Copyrights]
____________ IP Ownership
____________ Franchise And Licensing Issues
____________ Software R&D – Other Subsidiaries
____________ Nondisclosure Agreement
____________ Short – Midterm Plans
____________ Accounting Systems
____________ Accounting Procedures – Monthly/Quarterly/Annually
____________ Agreements – Suppliers, Licensing, Distribution
____________ Secretary Of State Registration
18. 17
Start Up Checklist for New Businesses in the U.S.
3. Employee Matters
____________ Handbook On Employee Procedures
____________ Employee vs. Independent Contractor
Insurance
____________ Medical
____________ Life
____________ Disability
____________ Workers’ Compensation
____________ Employee Contracts
Stock Plans
____________ Nonqualified Plans
____________ Qualified Plans
____________ Option Plans
____________ Vesting Plans
____________ 409A Valuation Requires
____________ Payroll Setup
19. 18
Start Up Checklist for New Businesses in the U.S.
4. Foreign Companies Expanding Into The U.S.
____________ IP Transfers
____________ Will Foreign Parent Flip Into U.S. Structure
____________ Employee Relocations From Foreign Country
____________ States Where Business Is Located
____________ Licensing Activity With U.S. Clients
____________ Licensing Activity From Parent
____________ Licensing Activity From The U.S.
____________ Buy-Sell Or Commission Structure
____________ Transfer Pricing Study
____________ Assets Contributed Into U.S. Company – Capital Or Debt
____________ Cost Plus Sales Subsidiary
____________ Stock Options In U.S. Parent Or Subsidiary
____________ Totalization Agreements
____________ Use Of Income Tax Treaty
Employee Related
____________ Tax Equalization
____________ Per Diem Payments
____________ Tax Issues And Planning In Initial Year
____________ Pre-Arrival Checklist – Employees, Executives, Founders
____________ Tax Treaty Benefits – Company, Employees
____________ Visa Types
20. 19
Start Up Checklist for New Businesses in the U.S.
5. Foreign Investment In U.S. Real Property
____________ Corporate, Partnership, Or Trust Ownership Structure
____________ Multiple Properties Or Single
____________ Investment Or Development
____________ Expected Holding Period
____________ Debt Financing
____________ Branch Tax Issues For Foreign Corporation
____________ Portfolio Interest Exemption
____________ Avoiding Estate Tax
Withholding
____________ Partnerships Or Corporations
____________ Sale Of Property Certificate To Reduce Withholding
____________ Federal
____________ State
21. 20
Start Up Checklist for New Businesses in the U.S.
6. Tax Filing – Domestic
Individual Income Tax Returns
____________ (Form 1040) Federal
____________ (Form 540) California
____________ (Form 1040-ES) Estimates
____________ (Form 1041) Trust & Estate
Corporate Income Tax Returns
____________ (Form 1120) Federal
____________ (Form 100) State
Partnership Income Tax Returns
____________ (Form 1065) Federal
____________ State
____________ K-1 Reporting
____________ (Form 990) Private Foundation
Other Forms
____________ (Form 2848) Power Of Attorney
____________ (Form SS-4) Application For EIN
____________ (Form W-2) Wage and Tax Statement
____________ (Form W-4) Employee’s Withholding Allowance Certificate
____________ (Form W-7) Individual Taxpayer Identification Number
____________ (Form W-9) Taxpayer Identification Number
____________ Officers, Directors Annual Report
____________ (Form 541-L) Property Tax
___________ Local City Tax
____________ Sales Tax
22. 21
Start Up Checklist for New Businesses in the U.S.
7. Tax Filing – International
____________ (Form 1040NR) Federal Individual Income Tax Returns
(Nonresident Aliens and Foreign Trust)
____________ (Form 540NR) California
____________ (Form 1120F) Foreign Corporation Income Tax Returns
____________ (Form 1065) Foreign Partnerships Doing Business In The U.S.
____________ (W-8BEN) Certificate Of Foreign Status Of Beneficial Owner
For United States Tax Withholding
____________ (W-8ECI) Certificate Of Foreign Person’s Claim For Exemption From
Withholding On Income Effectively Connected With Conduct Of A
Trade of Business In The U.S.
____________ (W-8IMY) Certificate Of Foreign Intermediary, Foreign Partnership
Or Certain U.S. Branches Of U.S. Tax Withholding
____________ (Form 926) Return By A U.S. Transfer Of Property To A Foreign Corporation
____________ (Form 1042) Annual Withholding Tax Return For U.S. Source Income
Of Foreign Person
____________ (Form 1042S) Foreign Person’s U.S. Source Income Subject To Withholding
____________ (Form 3520 Or Form 3520A) Annual Return To Report Transactions With
Foreign Trusts And Receipt Of Certain Foreign Gifts
23. 22
Start Up Checklist for New Businesses in the U.S.
7. Tax Filing – International – Continued
____________ (Form 5471) Information Return Of U.S. Persons With Respect To Certain
Foreign Corporations
____________ (Form 5472) Information Return Of 25% Foreign Owned U.S. Corporation Or
A Foreign Corporation Engaged In A U.S. Trade Or Business
____________ (Form 8804) Annual Return For Partnership Withholding Tax
____________ (Form 8805) Foreign Partner’s Information Statement of Section 1446
Withholding Tax
____________ (Form 8813) Partnership Withholding Tax Payment Voucher
____________ (Form 8832) Entity Classification Election
____________ (Form 8833) Treaty-Based Return Position Disclosure
____________ (Form 8854) Initial And Annual Expatriation Statement
____________ (Form8858) Transactions Between Foreign Disregarded Entity Of A Foreign
Tax Owner And the Filer Or Other Related Entities
____________ (Form 8865) Return Of U.S. Persons With Respect To Certain Foreign
Partnerships
____________ (Form 8873) Extraterritorial Income Exclusion
____________ (Form 8913) Credit For Federal Telephone Excise Tax Paid
____________ (FinCEN Form 114) Report Of Foreign Bank And Financial Accounts
24. 23
Start Up Checklist for New Businesses in the U.S.
8. Pre-Arrival Checklist
____________ Consider establishing a foreign or U.S. trust for estate planning purposes.
If assets are located in one’s country of origin, it may be necessary to consult
with local counsel to coordinate legal and tax issues. The use of trusts may not
work in civil law jurisdictions, e.g. France and Germany
____________ Determine if accelerating gift planning or contemplated sales of assets prior to
entering the U.S. will save global tax
____________ Explore tax strategies that will step up the tax basis of assets to their fair market
value so only appreciation after becoming a U.S. resident will be taxable in the
U.S.
____________ Review existing investment structures to determine whether there will be
adverse tax impacts under U.S. tax laws
____________ Stock options, when exercised, usually generate ordinary income in the U.S.
that is taxable at the top rate of 39.6% Consider exercising options prior to
arrival.
____________ Review deferred compensation and retirement benefits, to determine how to
efficiently access these sources with minimum tax before and after arrival. If
you have a foreign stock plan, you should check whether vesting will be taxable
to you after entering the U.S.
25. 24
Start Up Checklist for New Businesses in the U.S.
8. Pre-Arrival Checklist – Continued
____________ Plan the proper timing for arrival. Arriving in the last half of the calendar year
will usually result in nonresident status for the full year. Foreign income and
capital gains during the year should then be exempt from U.S. tax.
____________ If you are being relocated to the U.S., consider whether you should be
employed by the U.S. or foreign affiliate and whether you should be covered
by social security in the U.S. or in your home country.
____________ If you are in the U.S. for a short period of time, you may be exempt from U.S.
tax under the relevant income tax treaty.
____________ Transferring appreciated assets to a foreign trust or foreign company will
usually trigger current income tax on the appreciation if the transfer is made
when you are a U.S. resident.
____________ Expatriation: If after 7 years of residence as a green card holder, you relinquish
your green card and leave the U.S., you may be subject to an exit tax on
appreciated assets. To minimize this risk, you may wish to defer getting your
green card if your stay in the U.S. is not permanent.
____________ Reporting bank balances and foreign investments is required under Federal and
State rules.
26. 25
1. Consider establishing a foreign or U.S. trust for estate planning purposes. If assets are located in one’s
country of origin, it may be necessary to consult with local counsel to coordinate legal and tax issues. The
use of trusts may not work in civil law jurisdictions, e.g. France and Germany.
2. Determine if accelerating gift planning or contemplated sales of assets prior to entering the U.S. will save
global tax.
3. Explore tax strategies that will step up the tax basis of assets to their fair market value so only
appreciation after becoming a U.S. resident will be taxable in the U.S.
4. Review existing investment structures to determine whether there will be adverse tax impacts under U.S.
tax laws.
5. Stock options, when exercised, usually generate ordinary income in the U.S. that is taxable at the top rate
of 39.6%. Consider exercising options prior to arrival.
6. Review deferred compensation and retirement benefits, to determine how to efficiently access income
minimum tax before and after arrival.
7. Foreign stock plan: Check whether vesting will be taxable after entering the U.S. 83(b) election time may
have expired.
8. Plan your timing for arrival. Arriving in the last half of the calendar year will usually result in nonresident
status for the full year. Foreign income and capital gains during the year should then be exempt from U.S.
tax.
9. If you are being relocated to the U.S., consider whether you should be employed by the U.S. or foreign
affiliate and whether you should be covered by social security in the U.S. or in your home country.
Pre-Arrival Tax Planning Checklist for Executives
27. 26
10. If you are in the U.S. for less than 183 days in the year, you may be exempt from U.S. tax under the relevant income
tax treaty.
11. Transfer appreciated assets to a foreign trust or foreign company prior to arrival to avoid triggering tax will on the
appreciation.
12. Expatriation: If after 7 years of residence as a green card holder, you relinquish your green card and leave the US, you
may be subject to an exit tax on appreciated assets. To minimize this risk, you may wish to defer obtaining your green
card if your stay in the US is not permanent.
13. Reporting bank balances and foreign investments is required under federal and state rules. The following IRS forms
need to be filed:
- FinCEN 114 Foreign Bank Account Report – For balances in excess of $10,000
- Form 3520 Receipt of any distributions or benefits from a foreign trust
- Form 3520 Receipt of gifts or bequests over $100,000 from a foreign person
- Form 3520A Annual return for a foreign trust
- Form 5471 Return of U.S. person in certain foreign corporations
- Form 8865 Return of U.S. person in certain foreign partnerships
- Form 8621 Investment in a passive foreign investment company (e.g. foreign mutual fund)
- Form 8938 New in 2011 – Statement of foreign financial assets
Caution: Many foreign holding structures may fall within these reporting requirements.
Significant penalties will be assessed if appropriate reporting is not done.
Pre-Arrival Tax Planning Checklist for Executives (Cont.)
28. 27
Brian Rowbotham is the founder and partner in charge of the firm’s international tax practice. Mr. Rowbotham
has 35 years of experience in advising businesses and individuals on complex domestic and international
income and estate tax planning. He is the founding partner of Rowbotham & Company LLP which is almost
exclusively dedicated to businesses and investors needing domestic and international tax and accounting
services. His clients include private and public companies around the globe which consist of: U.S. and foreign
institutional investors, multinational families and executives and non-U.S. investors doing business in the U.S.
Mr. Rowbotham has advised clients in major domestic and international litigation and has also served on the
boards of both privately held and publicly traded companies.
He has given presentations on cross border tax strategies in Hong Kong, Shanghai, Guangzhou, Mumbai,
Singapore, and throughout Europe and the U.S. He is a frequent guest speaker at the Haas Business School,
UC Berkeley on international tax where he received his bachelors and MBA degrees. In 2012 he was awarded
the Distinguished Service Award by the California CPA Society for support of the profession and was featured
on the cover of the California CPA for doing business in China.
Email: br@rowbotham.com
Rowbotham & Company is based in San Francisco. Its practice is unique with its global clientele in Asia and Europe with many of its clients being foreign
institutions and ultra high net worth families investing in U.S. real estate. Clients include large institutional investors in the U.S., and real estate funds in the U.S.
and foreign countries. Projects in the past include real estate structures for joint ventures by foreign governments from Middle East (Kuwait, Qatar) and Germany.
Private investment structures involve large investment funds based in Europe and Asia and with publicly traded enterprises and high net worth families.
The firm’s practice in this area was established in 1990 and is well recognized as one of the premier firms on the West Coast with its consulting and advisory group of
experienced accountants and lawyers. The firm is a member of Geneva Group International, an organization of professional firms in over 100 locations worldwide.
Speakers Bio