When does a foreign business have to pay U.S. tax? It depends on whether the foreign business comes from a treaty or a non-treaty country. If subject to U.S. tax, it must pay at a 21% rate on its business income. This session will dive into the standards of imposing U.S. tax for businesses coming from a treaty (permanent establishment) or a non-treaty (trade or business) country. We will also discuss the determination of the branch profits tax.
Learning Objectives:
Reinhart Boerner Van Deuren s.c.
Chair of the International Department
[email protected]
(312) 207-5456
Robert Misey leads the International Department for the law firm of Reinhart Boerner Van Deuren and is a former trial attorney for the IRS Chief Counsel (International) in Washington, DC. Robert is Chair of the International Tax Committee for the ABA and a member of the bar in California, Wisconsin, and the District of Columbia. He is also the author of the book, A Practical Guide to U.S. Taxation of International Transactions and Federal Taxation: Practice and Procedure.