U.S. Inbound Business Tax Planning

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Over the past several decades, the pace and amount of foreign direct investment in the United States has increased dramatically. As a result, an increasing number of practitioners are called upon to advise foreign investors on the U.S. tax aspects of U.S. investments, acquisitions, restructurings, and dispositions. This webinar will discuss certain key issues involving the formation, operation, restructuring, and disposition of foreign investments by non-U.S. investors, from both a U.S. federal and state tax perspective.

This practical webinar from Bloomberg BNA, presented by Bernard Moens, Sidney Silhan, and Eileen Scott, provides participants with valuable information regarding the U.S. federal and state income taxation of foreign persons investing or looking to invest in the United States, and discusses the common issues affecting foreign activity in the United States.

During this recorded webinar, the presenters will cover:
• The framework of U.S. inbound income taxation 
• State tax considerations related to U.S. inbound income taxation
• Tax-related issues in connection with the formation of a U.S. business
• State tax credits and incentives 
• Fundamentals and planning involving the financing of U.S. subsidiary operations 
• Inbound mergers and acquisitions, dispositions, and restructurings

Educational Objectives
• Determine when foreign persons and companies investing in the United States are generally subject to U.S. taxation
• Identify the different forms in which a foreign company may establish U.S. subsidiary operations
• Distinguish between the tax consequences under U.S. tax law versus treaty principles in the context of inbound planning
• Determine tax collection responsibilities between U.S merchants and foreign merchants
• Apply state tax nexus and state filing obligation principles in the context of inbound planning
• Compare the tax consequences of an inbound company doing business in the major state jurisdictions (such as New York, California, Illinois and New Jersey)
• Identify state tax credit and incentive considerations for inbound planners



Bernard Moens, Lic. Lur., LL.M., is an international tax services principal with PricewaterhouseCoopers’s Washington National Tax Services office, where he leads the firm’s national inbound practice. Bernard has advised numerous large foreign multinationals on their U.S. acquisitions, financings, refinancings, and licensing transactions involving several countries, and has assisted clients in obtaining private letter rulings involving complex treaty issues. Bernard is a member of the American Bar Association and the International Fiscal Association, and is Adjunct Professor at the Georgetown University Law School. He is co-author of Bloomberg BNA Tax Management Portfolio on U.S. Inbound Business Tax Planning (6580), and other articles and publications, and is a frequent speaker on topics involving U.S. international tax. 


Sidney Silhan, J.D., CPA, is a partner with EY, National Indirect/State and Local Tax practice in Atlanta, and is National Practice leader of the Lookback Review Practice at EY. Sidney has nearly 20 years of experience in state and local tax and corporate structuring and merger and acquisition issues. He also advises in the areas of controversy, tax structuring, consulting and compliance matters. Prior to joining EY, Sidney spent 13 years with PricewaterhouseCoopers, most recently as the state and local tax M&A leader for the Southeast. He is co-author of Bloomberg BNA Tax Management Portfolio on U.S. Inbound Business Tax Planning (6580), and regularly writes and speaks about state tax issues.


Eileen Scott, Ph.D., MPA, is a director in the International Tax Services group of PricewaterhouseCoopers’s Washington National Tax Services office, where she is a core member of PwC’s national inbound team, focusing on cross-border activities of foreign multinationals, including inbound financing and restructuring, income tax treaty analysis, U.S. withholding requirements, among others. She is a member of the U.S. branch of the International Fiscal Association.  Eileen co-authored the Bloomberg BNA Tax Management Portfolios on U.S. Inbound Business Tax Planning (6580) and on U.S. Income Tax Treaties (938), and she is a frequent contributor to PwC publications on U.S. inbound tax and tax treaty topics.