This document discusses various offshore structures and tax reporting considerations for US persons with foreign assets. It notes that while having foreign accounts is legal, evading taxes is not. It describes "disregarded entities" and forms like 8832 that can elect to treat foreign entities as disregarded for tax purposes. However, it suggests that alternative structures providing more privacy and tax benefits than disregarded entities exist, though consulting is needed to understand the appropriate strategy.
Gone are the days of corporate secretary duties performed in isolation. General counsel are under increasing pressure to deliver and demonstrate value to the organization. [Legal entities proliferate]. [New tax laws] and [privacy regulations like the GDPR] force a reassessment of legal structures.
Managing legal entities efficiently is critical for general counsel balancing legal, risk management, and leadership responsibilities. This presentation provides a comprehensive review of [entity management as a legal practice] and [entity management software ]as a tool from the perspective of the general counsel and in house legal team.
Gone are the days of corporate secretary duties performed in isolation. General counsel are under increasing pressure to deliver and demonstrate value to the organization. [Legal entities proliferate]. [New tax laws] and [privacy regulations like the GDPR] force a reassessment of legal structures.
Managing legal entities efficiently is critical for general counsel balancing legal, risk management, and leadership responsibilities. This presentation provides a comprehensive review of [entity management as a legal practice] and [entity management software ]as a tool from the perspective of the general counsel and in house legal team.
Entrepreneurs will face a huge number of decisions as they move from concept to commercialization. One of the
first major decisions is what type of legal entity to form in order to move their great ideas forward. Why does it
matter? Because different entities have very different rules regarding limited liability, management and control
flexibility, capital structure, tax efficiency and eligible investors.
Final top ten mistakes startups make 09.23.2014 (00046831x c0cb4)Roger Royse
LEARN FROM THE EXPERTS. EXPERIENCED CFO AND ATTORNEY WILL DISCUSS OBVIOUS AND AVOIDABLE MISTAKES COMMONLY MADE BY STARTUPS IN THEIR EARLY YEARS.
Financial and legal mistakes go hand in hand and often overlap. This interactive "conversation" between a CFO and an attorney will shed light upon these common mistakes, as well as provide solutions for avoiding common pitfalls. This webinar is geared towards current and future executives at startups, financial and legal advisors of startups, and students considering starting their own businesses.
Speakers: Lisa Chapman, Esq. - Royse Law Firm
Chris Chillingworth - Partner at CFOs2Go
Moderator: Fred Greguras, Esq. - Royse Law Firm
Small and medium sized businesses are the engines which drive the North American economy. Increasingly, people go in to their own business. Often spouses and other family members are in business together. Because of mutual trust and sharing which exists at the start of these arrangements, spouses tend not to make agrements about what will happen if the marriage breaks down.
When spouses who are in business together divorce, there are also consequences for the business. Who will keep the business? What will the spouses be able to work together? How much is the business worth? Who should buy the business? How will a buyout be funded? These questions are just the tip of the iceberg.
In this PowerPoint slide presentation, we provide useful information about the legal problems confronting separating or divorcing couples who are in business together. By reviewing these slides you will gain important insights about the issues lawyers have to deal with in these situations. What law applies? What other kinds of experts do you need? What legal advice will you need to find a workable resolution? What evidence will you need if the case has to go to trial? What procedure must be followed? If you are in business with your spouse or life partner, the information in these slides provides a few pointers about Ontario law even if the relationship is continuing. Sometimes, a unanimous shareholders’ agreement or some strategic advice can help avoid expensive litigation down the road.
These slides were part of a presentation at a lawyers conference conducted by Osgoode Professional Development in Toronto on March 27, 2012. They are intended as information only and not legal advice.
The authors are experienced litigation and arbitration lawyers in Toronto, Ontario, Canada, who act on complex shareholder disputes, typically involving closely-held corporations.
In this tutorial, Chris Roush helps you become better acquainted with the inner-workings of bankruptcy court and shows you best practices for identifying stories in documents.
Roush is the director of the Carolina Business News Initiative and an associate professor at the University of North Carolina at Chapel Hill.
This webinar is critical for entrepreneurs who will be raising a preferred round in the near future. This webinar is designed to teach you what to expect when your company sells preferred stock in a venture round.
During this webinar, veteran Silicon Valley venture capital attorney Jason Putnam Gordon will cover the following topics:
· What venture capitalists are looking for when they invest in a company
· What makes a company a potential investment for a venture capital fund
· Pre-round issues
· What makes a good investor and how to find them
· How to negotiate a term sheet
· The deal documentation
· The diligence process
· Closing issues
· Post-closing issues
· Common pitfalls when raising venture capital
· And much, much more
How To Relocate An International Startup to Silicon Valleyideatoipo
You began your startup outside of the United States, and now you would like to relocate it to Silicon Valley. Every year many startups make the move without working through the complex legal issues. Failing to address those issues can kill your startup. San Francisco-based startup and venture capital attorney Jason Putnam Gordon of Polsinelli LLP will provide a high-level overview of the common US legal issues surrounding the move. This program will provide information on the following key issues:
· Corporate structure
· Tax consequences
· Intercompany agreements
· Immigration
· Intellectual property issues
· US employment laws
· The Committee on Foreign Investment in the United States, also known as CFIUS
· Export-control Issues
· Common pitfalls and mistakes
· And much, much more.
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.
Entrepreneurs will face a huge number of decisions as they move from concept to commercialization. One of the
first major decisions is what type of legal entity to form in order to move their great ideas forward. Why does it
matter? Because different entities have very different rules regarding limited liability, management and control
flexibility, capital structure, tax efficiency and eligible investors.
Final top ten mistakes startups make 09.23.2014 (00046831x c0cb4)Roger Royse
LEARN FROM THE EXPERTS. EXPERIENCED CFO AND ATTORNEY WILL DISCUSS OBVIOUS AND AVOIDABLE MISTAKES COMMONLY MADE BY STARTUPS IN THEIR EARLY YEARS.
Financial and legal mistakes go hand in hand and often overlap. This interactive "conversation" between a CFO and an attorney will shed light upon these common mistakes, as well as provide solutions for avoiding common pitfalls. This webinar is geared towards current and future executives at startups, financial and legal advisors of startups, and students considering starting their own businesses.
Speakers: Lisa Chapman, Esq. - Royse Law Firm
Chris Chillingworth - Partner at CFOs2Go
Moderator: Fred Greguras, Esq. - Royse Law Firm
Small and medium sized businesses are the engines which drive the North American economy. Increasingly, people go in to their own business. Often spouses and other family members are in business together. Because of mutual trust and sharing which exists at the start of these arrangements, spouses tend not to make agrements about what will happen if the marriage breaks down.
When spouses who are in business together divorce, there are also consequences for the business. Who will keep the business? What will the spouses be able to work together? How much is the business worth? Who should buy the business? How will a buyout be funded? These questions are just the tip of the iceberg.
In this PowerPoint slide presentation, we provide useful information about the legal problems confronting separating or divorcing couples who are in business together. By reviewing these slides you will gain important insights about the issues lawyers have to deal with in these situations. What law applies? What other kinds of experts do you need? What legal advice will you need to find a workable resolution? What evidence will you need if the case has to go to trial? What procedure must be followed? If you are in business with your spouse or life partner, the information in these slides provides a few pointers about Ontario law even if the relationship is continuing. Sometimes, a unanimous shareholders’ agreement or some strategic advice can help avoid expensive litigation down the road.
These slides were part of a presentation at a lawyers conference conducted by Osgoode Professional Development in Toronto on March 27, 2012. They are intended as information only and not legal advice.
The authors are experienced litigation and arbitration lawyers in Toronto, Ontario, Canada, who act on complex shareholder disputes, typically involving closely-held corporations.
In this tutorial, Chris Roush helps you become better acquainted with the inner-workings of bankruptcy court and shows you best practices for identifying stories in documents.
Roush is the director of the Carolina Business News Initiative and an associate professor at the University of North Carolina at Chapel Hill.
This webinar is critical for entrepreneurs who will be raising a preferred round in the near future. This webinar is designed to teach you what to expect when your company sells preferred stock in a venture round.
During this webinar, veteran Silicon Valley venture capital attorney Jason Putnam Gordon will cover the following topics:
· What venture capitalists are looking for when they invest in a company
· What makes a company a potential investment for a venture capital fund
· Pre-round issues
· What makes a good investor and how to find them
· How to negotiate a term sheet
· The deal documentation
· The diligence process
· Closing issues
· Post-closing issues
· Common pitfalls when raising venture capital
· And much, much more
How To Relocate An International Startup to Silicon Valleyideatoipo
You began your startup outside of the United States, and now you would like to relocate it to Silicon Valley. Every year many startups make the move without working through the complex legal issues. Failing to address those issues can kill your startup. San Francisco-based startup and venture capital attorney Jason Putnam Gordon of Polsinelli LLP will provide a high-level overview of the common US legal issues surrounding the move. This program will provide information on the following key issues:
· Corporate structure
· Tax consequences
· Intercompany agreements
· Immigration
· Intellectual property issues
· US employment laws
· The Committee on Foreign Investment in the United States, also known as CFIUS
· Export-control Issues
· Common pitfalls and mistakes
· And much, much more.
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 is one of presentations from the 2009-2010 Game Industry Start Up Workshop Series. The first workshop topic was "How to Form and Protect Your Business" and it took place on 9/15/09.
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.
Here's my "Artist's Guide To Owning & Operating a Business." It's for creative entrepreneurs that want to help get their business up and running quickly. Contact my office to supercharge the findings in my report!
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!
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.
Visualizing what SLS GLOBAL LLC can do for me.SLS GLOBAL LLC
SLS GLOBAL is a master logistics firm specializing in the art of going offshore for the first time. We help clients with a burning desire to liquidate & move their assets offshore in privacy from start to finish.
Receive guidance from people living the dream overseas.
Corporate Structures World Wide
Global Bank & Brokerage Accounts
Physical Metals, Storage, & Real Estate
Liquidation, Auctions, & Managed Accounts
Experienced Virtual Logistics & Asset Protection Facilitators- We handle all the paperwork with you, Spanish interpretation, setting appointments, facilitated meetings, reading Spanish contracts before you sign, representing your interests
Panama, the logical hub of the Western Hemispher. Rich with water, fertile soil, ground level opportunity for Pioneers, and a place for recycling in combination with the science of Kangen Water. Invest in Potrerillos Chiriqui, Panama thanks to The Panama Insider Reports.
Supply Chain Management through the advent of digital mobile money and smart phone apps.
How to Navigate Panama Like a Pro by Ellen RingSLS GLOBAL LLC
International Living 2011 guest speaker Ellen Ring gives you practical actionable nuts and bolts overview of how to Navigate Panama faster and easier with professional specialized guidance.
Securing your Kubernetes cluster_ a step-by-step guide to success !KatiaHIMEUR1
Today, after several years of existence, an extremely active community and an ultra-dynamic ecosystem, Kubernetes has established itself as the de facto standard in container orchestration. Thanks to a wide range of managed services, it has never been so easy to set up a ready-to-use Kubernetes cluster.
However, this ease of use means that the subject of security in Kubernetes is often left for later, or even neglected. This exposes companies to significant risks.
In this talk, I'll show you step-by-step how to secure your Kubernetes cluster for greater peace of mind and reliability.
Epistemic Interaction - tuning interfaces to provide information for AI supportAlan Dix
Paper presented at SYNERGY workshop at AVI 2024, Genoa, Italy. 3rd June 2024
https://alandix.com/academic/papers/synergy2024-epistemic/
As machine learning integrates deeper into human-computer interactions, the concept of epistemic interaction emerges, aiming to refine these interactions to enhance system adaptability. This approach encourages minor, intentional adjustments in user behaviour to enrich the data available for system learning. This paper introduces epistemic interaction within the context of human-system communication, illustrating how deliberate interaction design can improve system understanding and adaptation. Through concrete examples, we demonstrate the potential of epistemic interaction to significantly advance human-computer interaction by leveraging intuitive human communication strategies to inform system design and functionality, offering a novel pathway for enriching user-system engagements.
DevOps and Testing slides at DASA ConnectKari Kakkonen
My and Rik Marselis slides at 30.5.2024 DASA Connect conference. We discuss about what is testing, then what is agile testing and finally what is Testing in DevOps. Finally we had lovely workshop with the participants trying to find out different ways to think about quality and testing in different parts of the DevOps infinity loop.
GDG Cloud Southlake #33: Boule & Rebala: Effective AppSec in SDLC using Deplo...James Anderson
Effective Application Security in Software Delivery lifecycle using Deployment Firewall and DBOM
The modern software delivery process (or the CI/CD process) includes many tools, distributed teams, open-source code, and cloud platforms. Constant focus on speed to release software to market, along with the traditional slow and manual security checks has caused gaps in continuous security as an important piece in the software supply chain. Today organizations feel more susceptible to external and internal cyber threats due to the vast attack surface in their applications supply chain and the lack of end-to-end governance and risk management.
The software team must secure its software delivery process to avoid vulnerability and security breaches. This needs to be achieved with existing tool chains and without extensive rework of the delivery processes. This talk will present strategies and techniques for providing visibility into the true risk of the existing vulnerabilities, preventing the introduction of security issues in the software, resolving vulnerabilities in production environments quickly, and capturing the deployment bill of materials (DBOM).
Speakers:
Bob Boule
Robert Boule is a technology enthusiast with PASSION for technology and making things work along with a knack for helping others understand how things work. He comes with around 20 years of solution engineering experience in application security, software continuous delivery, and SaaS platforms. He is known for his dynamic presentations in CI/CD and application security integrated in software delivery lifecycle.
Gopinath Rebala
Gopinath Rebala is the CTO of OpsMx, where he has overall responsibility for the machine learning and data processing architectures for Secure Software Delivery. Gopi also has a strong connection with our customers, leading design and architecture for strategic implementations. Gopi is a frequent speaker and well-known leader in continuous delivery and integrating security into software delivery.
SAP Sapphire 2024 - ASUG301 building better apps with SAP Fiori.pdfPeter Spielvogel
Building better applications for business users with SAP Fiori.
• What is SAP Fiori and why it matters to you
• How a better user experience drives measurable business benefits
• How to get started with SAP Fiori today
• How SAP Fiori elements accelerates application development
• How SAP Build Code includes SAP Fiori tools and other generative artificial intelligence capabilities
• How SAP Fiori paves the way for using AI in SAP apps
Transcript: Selling digital books in 2024: Insights from industry leaders - T...BookNet Canada
The publishing industry has been selling digital audiobooks and ebooks for over a decade and has found its groove. What’s changed? What has stayed the same? Where do we go from here? Join a group of leading sales peers from across the industry for a conversation about the lessons learned since the popularization of digital books, best practices, digital book supply chain management, and more.
Link to video recording: https://bnctechforum.ca/sessions/selling-digital-books-in-2024-insights-from-industry-leaders/
Presented by BookNet Canada on May 28, 2024, with support from the Department of Canadian Heritage.
Elevating Tactical DDD Patterns Through Object CalisthenicsDorra BARTAGUIZ
After immersing yourself in the blue book and its red counterpart, attending DDD-focused conferences, and applying tactical patterns, you're left with a crucial question: How do I ensure my design is effective? Tactical patterns within Domain-Driven Design (DDD) serve as guiding principles for creating clear and manageable domain models. However, achieving success with these patterns requires additional guidance. Interestingly, we've observed that a set of constraints initially designed for training purposes remarkably aligns with effective pattern implementation, offering a more ‘mechanical’ approach. Let's explore together how Object Calisthenics can elevate the design of your tactical DDD patterns, offering concrete help for those venturing into DDD for the first time!
Accelerate your Kubernetes clusters with Varnish CachingThijs Feryn
A presentation about the usage and availability of Varnish on Kubernetes. This talk explores the capabilities of Varnish caching and shows how to use the Varnish Helm chart to deploy it to Kubernetes.
This presentation was delivered at K8SUG Singapore. See https://feryn.eu/presentations/accelerate-your-kubernetes-clusters-with-varnish-caching-k8sug-singapore-28-2024 for more details.
Key Trends Shaping the Future of Infrastructure.pdfCheryl Hung
Keynote at DIGIT West Expo, Glasgow on 29 May 2024.
Cheryl Hung, ochery.com
Sr Director, Infrastructure Ecosystem, Arm.
The key trends across hardware, cloud and open-source; exploring how these areas are likely to mature and develop over the short and long-term, and then considering how organisations can position themselves to adapt and thrive.
![OFFSHORE US TAX REPORTING For DISQUALIFIED ENTITIES ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]](https://image.slidesharecdn.com/foreignustaxreporting-111125210307-phpapp01/85/Foreign-us-tax-reporting-1-320.jpg)
![Disclaimer ,[object Object],[object Object],[object Object]](data:image/gif;base64,R0lGODlhAQABAIAAAAAAAP///yH5BAEAAAAALAAAAAABAAEAAAIBRAA7)