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United States entity considerations in the Trump era
Published on 01 Apr 18 by "THE TAX SPECIALIST" JOURNAL ARTICLE
The introduction of the Trump reforms is reshaping the way businesses and private clients analyse entity choice within the US and abroad. The way US corporations and flow-through entities are classified and taxed, and the choices available to taxpayers, have always created planning opportunities for Australian businesses expanding into the US and families investing in the US. Under the US “check-the-box” (CTB) regime, eligible entities such as limited liability companies, Australian general and limited partnerships, Australian unit trusts and Australian proprietary limited companies can elect for their tax classification as either a corporation or transparent entity, subject to certain requirements. This article provides an overview of the CTB regime and the US income tax issues that drive entity choice. This is important for Australian businesses who are expanding into the US and families that are investing in the US, with particular focus on the new tax reform rules introduced by President Trump.
Author profiles
Peter Harper
Peter is the CEO of the Asena Group, a multi-family office. He has spent most of his career advising foreign-owned, privately held businesses and family offices on global structuring and US inbound investment. Peter's core focus is extracting value for family offices, and he believes in a “stakeholder framework” to corporate taxation. The “stakeholder framework” encompasses the development of a tax strategy that facilitates value for families, rather than for the portfolio companies that they invest in or manage. - Current at 20 April 2020
Jurate Gulbinas
Jurate holds a Bachelor of Literature degree, a Masters of Business Administration from the National University in San Diego, and a Master of Science in Taxation from Golden Gate University in San Francisco. She also received a Certificate in International Taxation from Golden Gate University. Jurate specialises in cross-border tax and compliance issues for both individual and business clients. Jurate is a member of the American Society of Public Accounts, the California Society of CPAs, and the Accounting and Financial Women’s Alliance.Current at 1 March 2017
Matthew Marcarian CTA
Matthew is a Principal at CST Tax Advisors. - Current at 30 September 2020Aman Mullee
Amanvir is an Australian tax lawyer and an expert in US–Australian cross-border tax issues. Amanvir has experience working on complex international M&A transactions in his previous position in deal advisory tax for a Big 4 accounting firm. Amanvir has completed his CTA level 2 and is a qualified solicitor in New South Wales. Amanvir specialises in advising privately held businesses on international tax issues, and entrepreneurs and executives on the taxation impact of relocating between the US and Australia. Amanvir has advised listed companies, entrepreneurs and family offices on a broad range of international tax issues, including to income tax, capital gains tax and estate planning.Current at 1 March 2017
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