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  • HOME
  • WHAT WE DO
    • International & Multi-state tax
    • Business Consulting & Tax
    • Not-for-profit
  • WHO WE ARE
    • Our Misson
    • Commitments for Excellence
    • Jae K. Choi. CPA, MST
    • Useful Information
  • News
  • CONTACT US
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  • International & Multi-state tax
  • Business Consulting & Tax
  • Not-for-profit

YOU ARE SPECIAL
WE ARE DIFFERENT
YOU ARE SPECIAL WE ARE DIFFERENT
YOU ARE SPECIAL
WE ARE DIFFERENT
YOU ARE SPECIAL WE ARE DIFFERENT
YOU ARE SPECIAL
WE ARE DIFFERENT
YOU ARE SPECIAL 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)

U.S. shareholders of CFCs may pay tax on the CFCs’ earnings even before actual distributions from the CFCs. A foreign corporation is a CFC if 50%+ stocks are owned by U.S. shareholders. The Tax Cuts and Jobs Act of 2017 added one-time transition tax and GILTI provisions. The Code and the Regulations provide various exceptions, exemptions, and elections to the taxes. The court cases and the Revenue Procedures confirm those escapes. Assess your situations, plan ahead, and avoid surprise. Choi & Partners help you:
  • 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)

U.S. persons may pay taxes more than usual if invested in PFICs. A foreign corporation is a PIFC if 75% of the corporation’s income is passive, or 50% of the corporation’s assets are held for production of passive income. Foreign private equity funds are PFICs. Foreign ETF, mutual funds, index funds could be PFICs. If proper elections neither available nor timely made, growth in PFICs may be subject to the highest rate of tax beyond the favorable qualified dividends and capital gain tax rate. Choi & Partners help you:
  • Evaluating PFIC tax risks and alternatives
  • Guiding PFIC administrators to provide QEF information to investors
  • Structuring PFIC to avoid unfavorable tax result

FBAR & FATCA

FBAR and FATCA are not special tax provisions anymore. These notorious acronyms were fear to many U.S. persons. More than million U.S. persons came forward to correct wrong-doings in the past. Hundreds of thousands of U.S. persons hiccupped with harsh penalties and imprisonments. Now is the time to understand the U.S. government’s intention and plan for the future. Choi & Partners help you:
  • 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

Foreign persons pay taxes to the U.S. only on income earned in the U.S. territory. This plain statement is not that simple when applying your situations into tax laws. International tax laws, especially in inbound tax, are full of surprise. Choi & Partners help you:
  • 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

Tax home is an essential concept in the U.S. and state tax laws. It is where you live to most of taxpayers. Mobility may shake this common definition, as are true to professional athletes and performing artists. If you are in one of these professions, you may have multiple tax homes. You may pay taxes to cities and states where you earn income. Deductions can be different from those with one tax home. Choi & Partners help you:
  • 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

Income is receipts in excess of expenditures. Tax is based on taxable income. This simple idea is not that simple, especially in tax laws. The Revenue Code is thicker than the Bible. The rulings and the court cases are million times voluminous than the Code. The key factor is not only how to operate a business. It is also how to plan a business, how to organize a business, how to establish an entity, how to transfer ownership and how to wind down the business. Choi & Partners help you:
  • 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

More than 50% of the U.S. production is from real estate business. Developers, contractors, designers, construction manufacturers, renters, brokers, mortgagees, insurance, etc. Real estate business is a living creature. We observed how the pandemic changed the industry. It will continuously change as the community demands. We need to understand the recent changes and to prepare for changes in the future. Not surprisingly, it is the most influential group to law makers and governments. This industry always demands exceptions and twists to the general rules.

Professionals (doctors & lawyers)

Professionals pursue special interests and expertise. They frequently join together and integrate their services. They sometimes separate for better efficiency. They need to structure their businesses to accommodate these changes. Choi & Partners help you:
  • 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

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