Key Tax Considerations for Non-U.S. Persons Investing in the United States

Cross-border business transactions and investments implicate various considerations from a U.S. federal income tax perspective. Non-U.S. persons investing in entities or assets in the United States, and their legal, accounting, and financial advisors, should be aware of certain key tax considerations that may impact such investors depending on the non-U.S. person's tax profile and the characteristics of the prospective investment. 

This program, presented by tax attorneys Xenia Garofalo and Sabrina Conyers, centers on the U.S. federal income tax consequences to a non-U.S. person for certain inbound U.S. investments and activities, with a particular focus on passive investments in private funds.

Learning Objectives: 

1. Identify the main U.S. federal income tax considerations for non-U.S. investors making U.S. investments

2. Discuss U.S. taxation of U.S. source income (including capital gains)

3. Gain an overview of "effectively connected income" versus "fixed or determinable annual or periodic income"

4. Examine investment structures that generate U.S. source income