|RIA International Portfolios – Tax Advisors Planning System includes the following titles available as a package or on an individual basis:
U.S. Taxation of Foreign Nationals Employed in the U.S.
As the world economy becomes more and more globalized, individuals increasingly work in several different countries during their career. As a result, the U.S. has a developed system for taxing foreign nationals who work in the U.S. This title explains how to plan for and comply with the U.S. tax rules regarding these foreign workers. Also included are various Practice Aids, such as an Election By a Qualified Alien to be Treated as a U.S. Resident; an Election By a Qualified Alien to Have a Dependent Child Treated as a U.S. Resident; and an Election to Treat a Nonresident Alien Spouse as a U.S. Resident.
U.S. Corporations Doing Business Abroad
This title provides a comprehensive discussion of the myriad of Internal Revenue Code provisions affecting U.S. corporations conducting business outside of the U.S. This title contains a thorough discussion of all major provisions affecting international transactions; including the organization and transfer of assets to foreign entities, the foreign tax credit provisions, subpart F and other anti-abuse provisions, the intercompany pricing rules and the complex foreign currency provisions. In addition to an explanation of the relevant law, the title provides numerous hypothetical and practical advice regarding specific types of transactions. It also identifies various pitfalls and planning opportunities that should be considered by a U.S. corporation conducting business outside the U.S.
Foreign Corporations Doing Business in the U.S.
With the extraordinary influx of foreign capital and goods into the U.S., an understanding of the U.S. taxation of foreign corporations doing business in the U.S. will enable such taxpayers to maximize their investment returns and enable U.S. tax planners to expand their practices. This title gives the U.S. based general tax practitioner a framework for analyzing the U.S. tax principles applicable to foreign businesses operating in the U.S. It discusses the U.S. tax issues and problems that every foreign business will encounter when evaluating a business opportunity in the U.S. Among the topics addressed are the taxation U.S. source income and income effectively connected with a U.S. trade or business, the “branch profits” tax, the taxation of U.S. real property interests, IRS compliance requirements, and the impact of U.S. tax treaties.
Corporate Leasing Transactions
This title is designed to give tax advisors an understanding of the major issues typically involved in a tax-advantaged leasing transaction. It describes the structures typically employed in corporate lease financing transactions, different forms of ownership a corporate lessor’s investment can take, and the tax analysis applied to determine whether a corporate investor will be treated as the owner of leased property for federal tax purposes. It then describes the income tax consequences that follow from a corporate inv being treated as the owner of leased property. The title then describes the unique structures used and issues arising in international leasing transactions. Finally, it describes different tax indemnity agreements frequently used to allocate among the investor/lessor and the user/lessee the tax costs and risks resulting from these transactions.
Structuring International Transfers of Executives
There are a myriad of issues that arise when an employer decides to transfer an executive to an assignment outside of his home country. The employer will want to know how to structure the employment relationship, what service allowances and perquisites it should pay the transferring executive during the assignment, and whether it is subject to new withholding or reporting requirements. The executive will want to know what his U.S. and foreign tax liability will be, whether he will be subject to social security withholding, and how he can remain a participant in his home country employee benefit plans. This title presents an in-depth and organized discussion of the principal planning issues the employer and the executive need to address, both from the standpoint of outbound executive (e.g. U.S. expatriates working abroad) as well as inbound executives (e.g. foreign nationals working in the U.S.).