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Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Active Business Investments

Recorded on: Sep. 21, 2017
Running Time: 01:31:10

Full Transcript:



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Taken from the Web Program Basics of International Taxation 2017 San Francisco recorded September 2017 in San Francisco.

Tax Concerns for Foreign Persons Investing in the U.S. (Inbound Investments) – Active Business Investments [01:31:10]

• Effectively Connected Income (ECI) and permanent establishment consequences
• Branch profits tax imposition

John D. Bates, David L. Forst

The purchase price of this segment includes the following article from the Course Handbook available online:

  • Sullivan & Cromwell Client Memo: IRS Releases Chief Counsel Advice Memorandum 201501013, Treating a Foreign Fund with No Employees as Engaged in a Trade or Business in the United States Through the Lending and Underwriting Activities of the Fund’s Manager, and Clarifying Trading Safe Harbors (January 26, 2015)
    S. Eric Wang

Presentation Material

  • Foreign Persons Investing in the United States – Active Business Investments
    John D. Bates, David L. Forst
(s)
John D Bates ~ Baker & Hostetler LLP
David L Forst ~ Fenwick & West LLP
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