A client recently posed a question regarding insolvency. The client had a single member LLC with a significant amount of debt and significant personal assets. Their business was going under. Would personal assets (the client has a significant amount) be counted by the...
Tax planning to immigrate to the United States should commence before a foreign person applies for U.S. lawful permanent resident status (a green card). The key to pre-immigration tax planning is to control a client’s U.S. residency (or domicile) start date for U.S....
According to the World Bank, there are more than 160 million privately-owned small and medium-sized enterprises in the world employing more than 500 million people. Many of these businesses are family-owned, with tightly held shareholdings. They are very often...
Jacob Stein provides a brief overview on how the United States taxes its citizens and residents who do business in a foreign country. The U.S. has a different set of tax rules for Americans doing business abroad. Why? This is because the United States has a Worldwide...
Jacob Stein provides a detailed overview of inbound taxation (foreigners doing business or investing in the U.S.) focusing on important aspects such as income taxes applicable to non-resident aliens, pre-immigration planning, FIRPTA, and ownership structures for...
