What Happens when a U.S. Person Opens a Foreign Corporation?
If you are a U.S. person and decide to open a foreign corporation, be careful about the potential U.S. federal tax filings and taxes connected with that foreign entity.
A non-U.S. company is generally not subject to federal income taxes unless it generates income from U.S. sources, or it has U.S. ownership.
A foreign corporation must be mindful of two main federal tax issues:
1. U.S. trade or business risks and effectively connected income (ECI)
2. Controlled foreign corporation (CFC) rules
In this video, we cover some of the high-level issues for foreign entities with U.S. ownership.
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