United States entity considerations in the Trump era
Source: The Tax Specialist Journal Article
Published Date: 1 Apr 2018
The introduction of the Trump reforms is reshaping the way businesses and private clients analyse entity choice within the US and abroad. The way US corporations and flow-through entities are classified and taxed, and the choices available to taxpayers, have always created planning opportunities for Australian businesses expanding into the US and families investing in the US. Under the US check-the-box (CTB) regime, eligible entities such as limited liability companies, Australian general and limited partnerships, Australian unit trusts and Australian proprietary limited companies can elect for their tax classification as either a corporation or transparent entity, subject to certain requirements. This article provides an overview of the CTB regime and the US income tax issues that drive entity choice. This is important for Australian businesses who are expanding into the US and families that are investing in the US, with particular focus on the new tax reform rules introduced by President Trump.
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Details
- Published By: Peter Harper, Jurate Gulbinas, Aman Mullee, Matthew Marcarian CTA
- Published On:1 Apr 2018
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