BarbriSFCourseDetails
  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

U.S. Taxation of Foreign Individuals and Businesses: IRS Compliance and Enforcement

Impact of Tax Treaties, ECI vs. FDAP Income, Reporting Requirements, Exemptions, Deductions, Tax Credits

$347.00

This course is $0 with these passes:

CLE
ALL
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Description

Foreign individuals and businesses engaging in transactions or having assets and activities in the U.S. create tax presence and residency issues for such businesses and individuals. Tax professionals and advisers must have a solid understanding of U.S. tax treaties and applicable rules for foreign individuals and businesses and their interplay with current U.S. tax law.

Generally, noncitizens or non-U.S. enterprises with U.S. investments or business activities are subject to U.S. income tax only on their U.S.-sourced income, requiring tax advisers to conduct a careful analysis to determine their taxpayer status, connection to the U.S., eligibility for tax treaty benefits, and approaches to reduce their tax liability and U.S. reporting obligations.

For foreign businesses, the critical issue is whether nonresident employees currently present in the U.S. give rise to a U.S. trade or business or a permanent establishment for the foreign employer. Similarly, foreign individuals can be treated as U.S. residents for tax purposes if they meet the "substantial presence test."

Listen as our panel guides tax professionals and advisers in determining taxpayer status for non-U.S. citizens and businesses, reporting requirements and available mechanisms under current U.S. tax law, and best practices for taxpayers.

Presented By

Arianne R. Plasencia
Partner
Mcdermott Will & Schulte Llp - Washington

Ms. Plasencia focuses her practice on US & international tax and estate planning matters. She provides international and US income, gift, and estate tax planning for entities and high-net-worth individuals. Ms. Plasencia works closely with multijurisdictional families and advises on inbound investment planning. As part of this work, she counsels individuals investing in the United States, trustees of trusts with US beneficiaries, individuals moving to and from the United States, and families with members residing in multiple jurisdictions.

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Gregory M. Weigand
Partner
McDermott Will & Emery, LLP

Mr. Weigand focuses his practice on complex domestic and international tax matters for multinational companies, closely held businesses, investment funds and family offices and high-net-wealth individuals. He advises US and foreign-based publicly traded and privately held companies on domestic and international mergers and acquisitions, financing transactions, and global restructuring transactions. Mr. Weigand regularly advises on the tax aspects of complex domestic and international transactions and the formation, structuring, and operation of private equity funds and family offices. He is experienced in negotiating, drafting and documenting transactions involving corporations, partnerships and cross-border entities. In addition, Mr. Weigand regularly represents international businesses and individuals with structuring and reorganizing their US operations and investments, including a significant amount of US real estate-based transactions such as the purchase and sale of commercial real estate and hospitality-related assets.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, June 24, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. U.S. tax presence and residency rules
  2. Tax issues for non-U.S. individuals
  3. Tax issues for non-U.S. businesses
  4. Compliance and reporting challenges for taxpayers


The panel will review these and other key issues:

  • What is the impact of tax presence and residency of individuals and businesses?
  • What is the impact of the application of the "substantial presence test"?
  • What are the key issues stemming from the application of the "physical presence test" for purposes of determining U.S. trade or business or permanent establishment standards?
  • What allocation issues are present?
  • What are the steps to overcome regulatory and compliance challenges?