This panel addresses the basics of what is known in the international tax planning community as inbound tax planning, meaning tax planning for money or business flowing into the U.S.: 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 how is it taxed? And what are some of the statutory and treaty provisions that a non-U.S. person or company should be aware of that affect U.S. taxation? This panel addresses these basic, yet foundational, elements of tax planning for taxpayers that the Internal Revenue Code considers to be non-resident aliens or non-U.S. persons. American Bar Association Section of Taxation – 2016 May Meeting. May 7, 2016.
5/2016
