Internation Taxation

International taxation generally refers to the tax treatment of cross-national transactions. Since each nation has its own tax rules and the rules of one nation are rarely perfectly meshed with those of another, it is possible that income will be taxed more than once (sometimes referred to as double taxation) or that it will go untaxed by any jurisdiction. In principal, two methods of taxation have been distinguished for direct taxes such as personal and corporate income taxes: the territorial (or source) system of taxation and the worldwide (or residence) system. Under a pure source system, all income earned in a country is taxed by that country regardless of whether the earner is deemed to be foreign. A pure residence system taxes income regardless of where it was earned as long as the earner is deemed to be a resident of the country.

As long as those receiving income are classified by all countries in the same mutually exclusive way as residents or nonresidents, and all countries use the same method of taxation, there is no problem of double taxation. Double taxation problems arise because countries have different residency rules and tax systems. For example, some countries use a territorial system when defining income while others use a residence basis for determining what income is taxable. Further, no country uses the pure form of either of these systems.

SK Tax Associates advise and consult with businesses, individuals, offshore service providers and other entities on matters involving international tax issues and its impact on our client’s U.S. or offshore transactions and structures. Little planning now makes big difference down the road.

Our international taxation client is:

* U.S. Companies or Individuals presently with:
Offshore business operations
Offshore Income from any sources
Offshore Brokerage or Investment Accounts
Sales or other transactions with offshore persons and/or entities
Acquisition or ownership of foreign real estate

* U.S. Companies and Individuals seeking advice on:
Future or contemplated offshore transactions
Incorporation, entity planning & business set up in foreign countries
Transferal of assets out of the U.S.
Transfer pricing issues
Foreign ownership of U.S. real estate
Tax treaty issues with foreign jurisdictions
Use of export tax incentives to minimize global taxes
International tax strategies

* Non-U.S. based Offshore Service Providers desiring assistance with:
advice and consultation for their U.S. clients on transactions, structures, etc.
start-up planning for foreign investments in the U.S.
foreign ownership and disposition of U.S. real estate

*Foreign Companies and Investors conducting business activities in the U.S.

* U.S. citizens living offshore

SK Tax Associates does not sell offshore structures or entities. We will not engage in nor act as a party to any tax evasion schemes.