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.

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

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 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

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

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.

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

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 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

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International & Multi-state tax

Business Consulting & Tax

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