Foreign or U.S. Domestic Estate and Trust Accounting and Tax Compliance
USCANTAX has significant experience in dealing with U.S. and foreign estates and trusts.
For the executors of foreign or U.S. estates with U.S.-situs assets, U.S.-source ECI, or FDAP income, we can prepare the financial statements as well as the estate’s income tax return, Form 1041 or 1040NR
For the trusties of foreign trusts with U.S. owners (Grantor trusts), or beneficiaries (Grantor & Nongrantor trusts) and no U.S.-source income, USCANTAX can prepare financial statements, Distributable Net Income (DNI), Undistributed Net Income (UNI) calculations and Form 3520-A.
Let us advise you on the characterization and taxation of the estate or the trust for U.S. tax purposes .
Foreign Active Businesses in the U.S.
Non-U.S. businesses often get involved with the U.S. in a cross-border transactions even when had no intention to start a U.S. trade or business. There is a fine line, determined by U.S. domestic legislation, regulations and tax treaties, after the crossing of which a foreign business becomes subject to taxes on their income effectively connected (ECI) to the United States trade or business. Please visit our Resources page for links to more information on ECI.
USCANTAX offers you:
- Review of business model. Branch vs. U.S. subsidiary considerations
- Double Taxation Treaty Planning and Compliance
- U.S. State Nexus Studies, State Entity Structure (stand-alone, combined or consolidated tax return reporting)
- Preparation of Foreign Corporation Form 1120-F (treaty & branch), Form 5472, domestic corporation or partnership tax returns
- Preparation of Withholding Tax Reporting Forms W-8ECI, 1042 and 1099s.
U.S. Domestic Corporate & Partnership Tax Accounting & Compliance
- Income Tax Accounting Provision and Uncertain Tax Positions Disclosure – ASC 740 (FAS 109 and FIN 48)
- Preparation of corporate, combined and consolidated U.S. federal (Form 1120) and state income & franchise tax returns
- Preparation of U.S. partnership, LLC and S-Corp (Forms 1065) income/franchise tax returns
- Preparation of U.S. & foreign tax exempt and private charitable corporation income tax returns
- Domestic E&P, stock basis, UNICAP, loss utilization studies, bankruptcy and restructuring tax planning
- State tax optimization, nexus studies
U.S. Outbound Tax Services
- Preparation of Forms 5471, 8865, 8858, 926
- US foreign tax credit planning and calculations, preparation of Form 1118
- Preparation of foreign portion of US MNC’s tax provision and uncertain tax positions disclosure
- Construction, real estate developer & project manager income tax methods of accounting and returns
- Cross-border transportation & logistics companies
- Technology start-up companies, R&D studies and claims
- Taxation of legal damage awards
- Life, P&C and captive insurance company tax returns
- Gambling & horse breeding partnerships