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Foreign Entity Classification for the Growing Business

FOREIGN ENTITY CLASSIFICATION FOR THE GROWING BUSINESS

Cost Free
Presentation Length 1.5 hours

Recorded DateSeptember 1, 2023
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Foreign entities can be subjected to United States income tax requirements when their income is effectively connected to the United States. Such entities can create tax and reporting requirements for United States-based stakeholders as well. An often overlookedand unfortunately, often oversimplified considerationis how the foreign entity is classified for United States tax purposes. Critically, the United States maintains its own distinct rules for the classification of foreign entities, and those rules are in no way impacted by how the entity is taxed in its home jurisdiction! Join this webinar for an in-depth discussion of the relevant considerations in this context, including tax ramifications for foreign trusts, foreign corporations, and foreign pass-through entities.

Learning Objectives: 


  • Identify how foreign entities can be subjected to United States income tax requirements 

  • Determine how foreign entities can create tax and reporting requirements for United States-based stakeholders

  • Recall how a foreign entity is classified for tax purposes

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.

Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.

Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.

Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
 

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Rimon is a highly selective entrepreneurial firm that combines the dynamic client service, teamwork, and agility of a high-end boutique law firm with the deep multidisciplinary experience of a large global firm. Our clients consistently receive exceptional representation across twelve countries and five continents, from our all-star team of corporate, litigation, tax, intellectual property, entertainment, and private client attorneys.

Rimon's consistent excellence, commitment to the community, and innovation have been internationally recognized, including by Harvard Law School, Stanford Law School, Chambers, Best Lawyers, Super Lawyers, the Financial Times Innovation awards, the Atlantic, the American Bar Association's Legal Rebels, the Economist, the Recorder, and many more.

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Rimon's attorneys come with decades of experience before even joining Rimon. Rimon's attorneys were meticulously drawn from the top ranks of premier law firms, international corporations, and academia. They hold JDs, PhDs, LLMs, and MBAs from the best universities in the United States and abroad. They have worked on multi-billion dollar deals, have won bet-the-company litigation, and have run universities. Their experience and education ensure our clients receive consistently excellent and comprehensive counsel.