Basics of International Tax Planning

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In an increasingly interconnected world, business and investments often span outside the home country of the client. The ability to spot issues and provide practical solutions is essential when consulting with clients with international ties. This presentation will cover both “inbound” issues related to foreign clients coming to the U.S., as well as “outbound” issues related to U.S. clients investing abroad, and will cover some basics of estate planning for international clients. 

Key takeaways from this presentation will include understanding residency, and when a client is taxable as a “U.S. Person” for both income tax and estate tax purposes. Further, this presentation will cover international tax issues related to U.S. Persons investment abroad, including what constitutes a controlled foreign corporations (“CFCs”), deferral and anti-deferral rules under the subpart F regime and the PFIC regime, and foreign tax credits. 

This presentation will also provide common “inbound” issues, including when a foreign client is taxable in the U.S., the rules under FDAP, and rules related to U.S. trade or business and effectively connected income. In addition, this presentation will cover common issues related to investment in real property by nonresidents within the U.S., including application of the Foreign Investment in Real Property Tax Act (“FIRPTA”), including common planning strategies. 

Finally, this presentation will cover basic issues in the application of income tax treaties, taxability under a permanent establishment (“PE”), and common issues related to income sourcing. 


Educational Objectives
• Ability to spot common U.S. tax issues related to both “inbound” and “outbound” transactions. 
• Ability to determine the U.S. tax implications for a U.S. Person’s investment abroad 
• Ability to determine whether a nonresident is taxable in the U.S., and the potential tax exposure 
• Common planning techniques to help reduce or eliminate U.S. tax 

Who would benefit most from attending this program?


Business & Tax Attorneys and CPAs with clients with international business activities or international investments.


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Mehrdad is a partner at Harlowe & Falk LLP, where he provides tax consulting services to clients with international operations. His clients include both U.S. based companies that have expanded abroad and foreign companies with U.S. ties. He also consults with U.S. based exporting companies to determine whether they qualify for IC-DISC tax incentive benefits, and assists in both implementation and maintenance of IC-DISC structures. 
Mehrdad is also adjunct professor at the University of Washington School of Law, where he teaches a class on the international taxation of intellectual property. He is also an adjust professor at Golden Gate University’s Masters in Tax Program, where he teaches a class on the fundamentals of international tax. 

Mehrdad earned his LL.M. in tax from the University of Washington School of Law and is JD from Gonzaga University School of Law, magna cum laude. He is a member of the Washington State Bar Association.