Gregory M. McKenzie Partner Kelley Drye & Warren LLP USA will be attend Invest Pro UAE Dubai with presentation:” U.S. Tax Considerations for Inbound U.S. Investments”
Kelley Drye & Warren LLP
International corporate law firm with over 300 lawyers and professionals in 9offices, including: New York; Washington, D.C.; Los Angeles; Chicago; Brussels; & Mumbai (affiliate office)
Investing in the United States? Principal U.S. Tax Considerations
A.Federal Income Tax
B.Federal Estate Tax
C.State Income Tax
1.Direct Investment vs. Establishment of U.S. Business Entity
2.Gain from Sale Eligible for Capital Gain Tax Rate?
3.Tolerance for U.S. Tax Reporting?
4.Appropriate Mix of Debt and Equity in Capital Structure of U.S. Business Entity
5.Utilization of U.S. Attributes in Home Jurisdiction
Why do we care?
Non-citizens non-residents (“NCNRs”) who die owning U.S. situs property are subject to 40% U.S. federal estate tax on value of U.S. situs property