Inbound tax services for foreign-owned U.S. companies
Navigating tax challenges in the world’s largest economy
The U.S. market offers tremendous opportunities for foreign-owned businesses. But successfully capitalizing on those opportunities also means understanding and navigating a complex array of tax issues at the federal and state levels. Consider some common questions you must answer:
- Will your operation rise to the level of a permanent establishment?
- Should you form a U.S. subsidiary and, if so, what form of entity best fits your strategy?
- How will you structure your capital? Can you have too much debt?
- Will there be related-party transactions? Do you need a transfer pricing analysis and documentation?
- Do you understand your full range of compliance and reporting obligations?
- If you have a permanent establishment, what about your employees? Do you have appropriate policies in place to help them understand and address their tax needs?
- Will your U.S. operations create state and local tax obligations? In which jurisdictions? What will you need to file, and where?
RSM understands. We’ve helped companies from all over the world anticipate and address the tax challenges inherent in seizing opportunities in the United States. From big-picture questions like choice of entity to helping you determine which of the hundreds of potential registrations, forms and returns you must file—and in which jurisdictions you must file them—we’re ready to help at every step along the way.
Use this guide as a highlight to several topics of importance to companies entering or expanding in the U.S. market.
The IRS plans to move to a more issue-focused examination process rather than entity size which may result in more audits of middle-market taxpayers.
Purchasers of U.S. real property interests from foreign sellers may be required to withhold tax under FIRPTA rules.
Limitation on benefits provisions of most U.S. treaties may necessitate the review of treaty qualification in certain circumstances.