
WE ARE DIFFERENT

WE ARE DIFFERENT

WE ARE DIFFERENT
International & Multi-state tax
Investment-cross-the-border is not exclusive to big corporations anymore. Lots of small businesses have international exposure. FATCA and FBAR educate individuals can be international investors. Governments want to tax on income beyond the traditional tax regime. In addition, the U.S. consists of 50 states and 1 district which have different tax laws. Choi & Partners help you evaluate your tax risks and plan for better.
CFC (Controlled foreign corporation)
- Evaluating Subpart F including GILTI and other anti-deferral tax provisions
- Maximizing Foreign tax credit
- Repatriation planning including distribution of PTEP
- Structuring foreign entities for better tax result
- Planning for FDII deduction and IC-DISC incentive
PFIC (Passive Foreign Investment Company)
- Evaluating PFIC tax risks and alternatives
- Guiding PFIC administrators to provide QEF information to investors
- Structuring PFIC to avoid unfavorable tax result
FBAR & FATCA
- Disclosure of past non-compliance with the IRS
- Reporting FBAR, FATCA and related income annually
- Evaluating foreign investment including securities and real properties
- Planning for Foreign tax credit
ECI (Effectively Connected Income) and U.S.-source Income
- Structuring investment in U.S. real properties
- Planning for transactions with the foreign parent companies
- Analyzing treaty benefits
- Evaluating U.S. entity alternatives
- Reporting U.S. branch or subsidiary operations
Professional athlete & Performing artist
- Evaluating state tax risks including Income tax, Franchise tax and Gross receipts tax
- Analyzing income allocation rules unique to leagues and occupations
- Structuring U.S. entities to maximize business deductions
- Establishing and severing state residency
Business Consulting & Tax
Plan ahead and develop strategies. Strategic operations make money. Strategic establishments save taxes. Differentiate your business from others. Pay attention on taxes before the business becomes profitable. Choi & Partners help you evaluate your opportunities and plan for better.
Small Business, Family-owned Business & Start-up Business
- Establishing and evaluating strategic business plan
- Structuring entities and ownership for growth and preservation
- Designing procedures and internal controls
- Establishing and maintaining accounting records
- Compliance with payroll taxes
- Integrated individual income tax planning
- Wealth transfer planning
Real Estate Investment
Professionals (doctors & lawyers)
- Designing compensations between partners
- Cost analysis and operations review
- Planning mergers and acquisitions
- Structuring entities and ownership
- Succession planning and retirement planning
- Wealth management
NOT-FOR-PROFIT (Charitable Organization and Non-Operating Fund)
Not-for-profit is an integral part of the U.S. economy. Tax incentives are provided not only to organizations but also to contributors. The Revenue Code Section 501(c)(3) exempts certain entities from income tax. An organization should operate for exempt purposes, should not inure its earnings to private shareholders, and should not attempt influence legislations. Donors and grantors want to know about organizations before they contribute to them. They want to know the organizations are financially healthy and stable to maintain their programs, and efficient and ethical to spend their funds. Governments also want to know if they use the government funds as granted.
- Evaluating risks of Unrelated business taxable income and Lobbying expenditures
- Tax Compliance to maintain tax-exempt status
- Financial Audit