The focus of this module is to give the participants an understanding of the U.S. tax related issues when entering the U.S. market. The module will discuss the various considerations that foreign investors / companies need to take into account as they plan on expanding their operations into the U.S. market. These considerations include choice of entity, location of business from a state and local tax perspective, and various other federal and state tax matters.
In addition, the module will discuss the Foreign Investment in Real Property Tax Act which applies to all foreign companies investing in the U.S, and the different aspects of the act and what companies should pay attention to.
Finally, the module will discuss the implications of cash distributions out of the U.S. from a income and withholding tax perspective.