Avoiding Withholding Tax On Foreign Interest Payments

Law360 (September 17, 2018, 2:28 PM EDT) -- The United States taxes foreign nonresident individuals and foreign entities on two types of income. The first, effectively connected income, is active business income that is subject to U.S. income tax. The second, fixed, determinable, annual or periodic income, referred to as FDAP income, or what we would generally consider portfolio income is subject to a withholding tax regime. This article is going to deal with interest paid by a blocker corporation which is subject to the withholding tax regime.

Investment Structure for U.S. Inbound Real Estate Investment

In the typical inbound U.S. real estate investment structure, a U.S. corporation (known...

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