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Let me give you one example which illustrates very well the difference between US Domestic Tax Law and US International Tax Law. This comes actually, from sort of a combination of two cases in which I was involved. You have a situation where two clients come to a Business Lawyer and they say, “We want […]
Hello, my name is Eugene Sherayzen and I’m an international tax attorney and owner of Sherayzen Law Office, Ltd. Today, I would like to introduce to you one of the most feared pieces of US Tax Legislation that recently reshaped the entire legal landscape of International Tax Compliance. I’m talking about FATCA. Even an introduction […]
Let’s go to another chart. Remember when I said we were going to discuss a situation where a non-US person does not engage in US trade or business activities? In this case, we have to ask: Is this US-source income classified as FDAP income (fixed determinable, annual or periodic) FDAP income generally includes passive investment […]
Let’s suppose we find a US trade does exist. If it doesn’t, then we’ll talk about the FDAP a little bit later in the presentation. If a non-US person engages in US trade or business activities, then the next question is: Is the income that he derives connected to these US trade or business activities, […]
Let’s suppose it is indeed US-source income; then the next question that we have to deal with is whether this non-US person engages in US trade or business activities. Just to repeat myself, if it is not a US-sourced income, generally speaking, it’s not taxable; but you see here and there that in order to […]