| 
Before we delve into the subject matter of today’s discussion, I’d like to introduce myself so that you know a little bit about who I am and what it is I do. I know that about half of you already know but the other half does not. As I’ve just said in my crude French […]
The Tax Owner is really a Holder of Economic Interest, not necessarily the Legal owner of the actual entity. Let me clarify that with an example. Let’s say this is a Taxpayer; this is the LLC and he owns 100% of that LLC. The LLC owns 50% of the Limited Partnership. The Taxpayer owns 50% […]
US Owners: I listed out for you what US Owner means. It’s US Citizens, US Tax Residents, meaning Permanent Residents and a person who has satisfied the US Presence Test, Non-residents who declare themselves as Tax Residents for the purposes of filing a joint tax return are also considered to be US Owners. Residents of […]
The question of a Business Entity actually involves a complex analysis and I lay out some of it here; it is a very simplified analysis but basically the very first question that we have to ask is: Is there a Business Entity? I’m going to jump to the point 1b right away. Suppose that ‘Pierre’ […]
Once we decide that this is a business entity, then our next question we have to ask is: What type of an entity is it? There are three choices available when it comes to US International Tax Law: a Corporation a Partnership or a Disregarded Entity The equivalent here of a Disregarded Entity is precisely […]