The section of the Offshore Tax Seminar provides an overview of the U.S. tax rules for U.S. persons who operate a business outside the U.S. or have affiliated entities doing business outside the U.S., with an emphasis on the income tax treatment of e-commerce transactions. It covers the tax rules for the foreign earned income exclusion, the extra-territorial income exclusion, foreign partnerships, foreign limited liability companies, foreign corporations or IBCs and other aspects of doing business outside the U.S.

Table of Discussion Topics

• Income taxes for web-based profits 
• Other taxes on e-commerce operations 
• The allure of a tax-free web-based business 
• The expatriation alternative 
• Income taxes versus sales taxes or the VAT 
• Citizenship, residency and domicile 
• Worldwide income taxes and tax credits 
• Taxes on individual foreign source income 
• Taxes on corporate income 
• Specific exemptions for non-resident alien investors 
• Residency in a low tax country for non U.S. citizens 
• Worldwide income taxation 
• Tax credits to compensate for dual taxation 
• Exemptions for working and living abroad 
• Passthrough taxation 
• Entity classification election 
• Passthrough taxation for certain corporate income 
• Dual taxation of corporate profits 
• The ten-year tax on U.S. expatriates 
• Income taxation based on worldwide income 
• Tax credit for income taxes to foreign countries 
• Deduction for dividends from other corporations 
• Tax treatment of affiliated or related corporations 
• U.S. treatment of foreign based branches 
• Export sales incentives 
• Controlled Foreign corporations 
• Subpart F income ("tainted income") 
• Investment income 
• Sales to or purchases from a related person 
• Related party personal service income 
• Other categories of Subpart F income 
• U.S. source income 
• Transfer pricing 
• Gain on transfers to Foreign Corporation for stock 
• Passive Foreign Investment Companies 
• The Foreign Tax Credit and CFCs 
• U.S. source income 
• Effectively connected income 
• Substantial presence test 
• Branch profits tax 
• Sales into the U.S. from a foreign country 
• Orders generated by offshore web servers 
• With no U.S. based operations 
• With U.S. based operations 
• Nexus from Internet marketing affiliate sites 
• Foreign corporations doing business outside U.S.
• Checklist of U.S. Tax Reporting Forms for Foreign Operations 
• Appendix & Endnotes