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The Basics of U.S. Tax Planning for Non-U.S. Persons/Non-Resident Aliens

    This panel addresses the basics of what is known in the international tax planning community as inbound tax planning: When does a non-U.S. person become subject to U.S. taxation? What exactly is U.S. source income, effectively connected income (“ECI”), or a U.S. trade or business? And what are some of the statutory or treaty provisions that a non-U.S. person should be aware of that affect how he or she is taxed? This panel addresses these basic, yet foundational, elements of tax planning for individuals that the Internal Revenue Code considers to be non-resident aliens or non-U.S. persons. American Academy of Attorney-Certified Public Accountants – 2015 Annual Meeting & Education Conference. July 1, 2015.