This advanced course provides foreign investors, legal professionals, and tax advisors with a comprehensive, practice-oriented understanding of U.S. tax law as it applies to foreign-owned businesses. With the growing complexity of global operations and heightened IRS scrutiny, the course focuses on the structuring, compliance, and risk management strategies that must be implemented from the outset of U.S. market entry through long-term operations and potential exit.
Participants will gain hands-on legal training through real-world simulations, entity structuring exercises, treaty analysis, compliance frameworks, and exit planning. The course emphasizes corporate tax, withholding regimes, transfer pricing, cross-border structuring, and international reporting obligations.
Course Objectives
By the end of the course, participants will be able to:
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Identify key U.S. tax obligations and planning considerations for foreign-owned businesses.
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Structure inbound investment using tax-efficient entity types and treaty-advantaged routes.
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Navigate U.S. corporate income tax, branch profits tax, and withholding regimes.
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Assess transfer pricing risk and build defensible intercompany pricing strategies.
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Comply with reporting obligations (FATCA, Form 5472, BEPS, etc.) applicable to foreign-controlled entities.
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Advise clients on tax-efficient repatriation, reinvestment, and exit strategies.
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Collaborate effectively with accounting, tax, and legal teams in a cross-border environment.
