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Foreign Business & Investors

U.S. tax guides for foreign businesses and investors entering the U.S.: foreign-owned LLCs, Form 5472, Form 1120-F, FIRPTA, pre-immigration planning, and country-specific guidance.

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International & Treaties

Latin America U.S. Tax Planning: Country Guides for Mexico, Brazil, Colombia, Argentina, and Chile Country-by-country U.S. tax guide for Americans in Latin America and Latin American investors entering the U.S., with links to Mexico, Brazil, Colombia, Argentina, and Chile planning pages.
Form 8833: Treaty-Based Return Positions and When You Must Disclose Them Claiming a tax treaty benefit that overrides U.S. tax law often requires disclosure on Form 8833. Here's when the form is required, when it's waived, and why the treaty tie-breaker can be dangerous for green card holders.
U.S.-Mexico Tax Treaty: What It Covers and How It Applies The U.S.-Mexico tax treaty reduces double taxation on income earned across borders. This guide covers who it applies to, key provisions on dividends, interest, royalties, capital gains, and how it interacts with FBAR and FATCA.
FIRPTA: Foreign Sellers of U.S. Real Estate FIRPTA requires buyers to withhold 15% of gross proceeds when a foreign seller disposes of U.S. real estate. Here is how the withholding works, when certificates can reduce it, and how the sale is reported.
Foreign-Owned U.S. Rental Property Foreign nationals with U.S. rental property often face a harsh default tax regime unless the Section 871(d) election and nonresident filing stack are handled correctly. Here is how the rules work.
Section 1446 Withholding: U.S. Partnerships with Foreign Partners U.S. partnerships that allocate effectively connected income to nonresident partners must withhold under Section 1446 and file Forms 8804 and 8805, regardless of whether cash is distributed.
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