PODCAST · business
US Tax
by Heide Robson
The podcast for Australian accountants with US clients. Find the experts and information you need to optimise your clients’ cross-border tax position. Help your clients invest or expand from Australia into the US and from the US into Australia. Hosted on Acast. See acast.com/privacy for more information.
Episodes
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US 33 | American Kleptocracy
Hosted on Acast. See acast.com/privacy for more information.
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US 32 | US - AU Tax Questions
6 common questions and their answers Hosted on Acast. See acast.com/privacy for more information.
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US 31 | Expansion into the US
When your clients plan an expansion into the US, they will most likely ask you how to structure this. Should they just trade through their Australian entity? Or set up an entity in the US? Hosted on Acast. See acast.com/privacy for more information.
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US 30 | US Public and Private Markets
How you structure into US public and private markets depends on whether you invest for cash flow or capital growth. How should you structure your passive investments in the US? Set up a US entity or trade through your Australian entity? Hosted on Acast. See acast.com/privacy for more information.
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US 29 | State Tax Questions
There is a sharp distinction between the econcomic nexus for sales tax and the one for state income tax. Hosted on Acast. See acast.com/privacy for more information.
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US 28 | PL 86 - 272
We already mentioned PL 86-272 a number of times in past episodes. Frances Ellington mentioned it and then also Ed Antolin. Today let’s drill deeper because losing the protection that PL 86-272 grants you, can cost you a lot of money in state income taxes. While PL 86-272 is federal law and so...
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US 27 | State Tax Sourcing Rules
Let’s talk about state tax sourcing rules. How do you determine which income is taxable in which state? If you sell into California but also into lots of other states, how do you determine what is taxable in California and what is taxable in other states? That is the question that Ed Antolin of...
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US 26 | California Income Tax
In US update 24 Frances Ellington already gave you a first overview of Californian income tax. In this update let’s drill deeper with Ed Antolin of Vallejo Antolin Agarwal Kanter, or in short VAAK in Walnut Creek, California. Just like with federal income tax, you have to distinguish between...
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US 25 | California Sales Tax
Until June 2018 US sales tax was relatively straight forward. States could only charge you sales tax if you had a physical presence in the state, like a shop or a warehouse. But then came the famous court case South Dakota v Wayfair, and there the Supreme Court decided on the 21st of June 2018…
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US 24 | California State Taxes
In this episode let’s look at California state taxes. Frances Ellington of GHJ Advisors in Los Angeles will give you a very helpful insight about Calfiornia sales and use tax, income and franchise tax. And listen out for Public Law 86-272. That law might exempt your clients from Californian state...
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US 23 | US State Taxes
For your Australian clients there is a high chance that US federal taxes are zero thanks to the double tax agreement with the US. But most US states don't consider these agreements, so while your client doesn’t pay any federal taxes in the US, they most likely still pay state taxes. So for your...
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US 22 | US Tax Identifiers
No tax administration system works without tax identifiers. The ATO uses ACNs, TFNs and ABNs. The US uses SSNs, ITINs and EINs. Social security numbers (SSN) are used for tax purposes but also for social security. A social security number in the US is like an individual TFN plus a Centrelink’s…
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US 21 | Forms 1065 and 5742
As a multi member LLC, you have to file 1065, 5472, K1, K2, K3 as well as 8804 and 8805. For a foreign member of a multi member LLC there is 1065 and K1 and then possibly also K2 and K3 listing the income allocated to the partners and then 8804 and 8805 listing any tax that has been withheld. The...
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US 20 | s882 and s864 One More Time
Let’s look at s882 and 864 one more time. The term ‘limited force of attraction’ would make a good movie title, maybe a sequel to ‘The Accountant’. But putting Hollywood aside, The Limited Force of Attraction rule in s864 (c) (3) says that if you have a US Trade or business, then all your US...
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US 19 | s864 (c) IRC
In the last episode, we looked at s882 of the Internal Revenue Code which covers foreign corporations with a US Trade or Business. Today let’s look at s864 (c ) of the Internal Revenue Code, which defines effectively connected income (ECI). s864 is the definition section, and for us it is s864 (c…
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US 18 | s882: Foreign Corporations plus USTB
The answer is that US-sourced income that is not effectively connected and not FDAP - so-called 'Non-ECI non-FDAP income' - is not taxable in the US if derived by a foreign person. US Sourced Non-ECI Non-FDAP income is not taxable in the US. But the question in this episode is: Why? How can...
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US 17 | Multi Member LLC
Multi member LLCs - LLC’s with 2 or more partners - why this fear of multi member LLCs? f you have a multi member LLC, you have all the filing obligations, 1065, K1, K2, K3 and so on, but in addition - if your multi member LLC has a US trade or Business and hence effectively connected income…
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US 16 | Non-ECI Non-FDAP
Non-ECI Non-FDAP – how is US sourced income that is neither ECI nor FDAP taxed in the US if derived by a non-resident? This is the point of contention. One school of thought says that all US-sourced income is taxable in the US unless there is a specific exemption. But this is the minority. The...
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US 15 | LLC Income
Three factors determine how US primary tax law taxes LLC income – disregarding any treaty position: 1 – Source of Income: US or foreign-sourced? 2 – Business: US Trade or Business or not? 3 – Tax residency of partners: US persons or non-resident alien / foreign corporation? Learn more about this…
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US 14 | Single Member LLC
A single-member LLC is a popular way to sell from Australia into the US through a 3PL service. In this episode, Ross Treeby of Treeby Tax Limited will walk you through the US tax side of single member LLs. Hosted on Acast. See acast.com/privacy for more information.
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US 13 | US Taxation of Australian SMSFs
For US citizens living in Australia, the US taxation of Australian SMSFs is a huge question. Unfortunately, there is no easy answer. The US taxation of Australian SMSFs is complicated. In this episode, Marsha Dungog of Withersworldwide in San Francisco will walk you through the issues your...
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US 12 | Australian Trust Holds LLC
For an expansion into the US is it best if your Australian trust holds LLC interests directly? Rather than going through a C-Corp? Australian Trust Holds LLC Interests When you expand into the US, you very quickly look at significant tax leakage and double taxation. And this despite potentially...
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US 11 | Australian Loan to US
Should an Australian loan to US operations go to your US blocker? Or directly to your US trading entity? Let’s say your Australian holding wants to give a loan to its US operations. How should you structure this loan? Should the Australian holding loan to your US blocker or directly to your US...
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US 10 | LLC Plus Blocker
Using an LLC plus blocker is a popular setup among Australian businesses entering the US market. In this episode, Marsha Dungog of Withers in San Francisco will tell you how and why. Hosted on Acast. See acast.com/privacy for more information.
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US 9 | Australian Companies in US Returns
You either just show dividends paid or you have to use a look-through approach for Australian companies in US returns. How are Australian companies picked up in US returns? So-called 1040s? Do you just record the dividend as income when paid? Or is it a look-through approach and you recognise...
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US 8 | LLC or C-Corp
As a non-US tax resident, should you run your US business through an LLC or C-Corp? If you use a C-Corp blocker, should your trading entity sit within an LLC or C-Corp? This is the questions Alfonso Nuñez of Andersen in San Francisco will discuss with you in this episode. Here is what we learned...
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US 7 | US Corporations
When you expand your business into the US, what types of US corporations are there to choose from? When your clients expand their business into the US, you will need one or two US corporations to optimise their US tax affairs. But what type of corporation? That is the question Al Nunez of…
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US 6 | US Stimulus Cheques
In March and December 2020 all eligible US residents received US stimulus cheques. How do you treat those in Australian tax returns? For US purposes stimulus cheques are refundable tax credits and as such are not recognised in Australian tax returns. But don’t take our word for it. Seth Hertz of...
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US 5 | US Individual Tax Return (Form 1040)
How do you ‘read’ an US individual tax return for Australian tax purposes? Your US clients will probably give you their US individual Tax Return – also referred to as Form 1040 – which you then build into their Australian tax return. But how do you ‘translate’ this form into an Australian tax...
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US 4 | US v Australian Tax for Individuals
US v Australian tax for individuals – how do you ‘translate’ a US tax return into an Australian tax return? US citizens living in Australia are tax residents and hence assessable on their world-wide income in both countries. But what does this look like in practical terms? How are Australian...
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US 3 | US Tax For Individuals
Whenever your client is a US citizen or Green Card holder, you will probably need to consider the rules around US tax for individuals. To help you look after your US clients, we asked Seth Hertz – Tax Director of Expat US Tax – for a general overview of US tax for individuals. Hosted on Acast.…
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US 2 | US Nonresident Alien Spouse
Aliens do exist. There are around 7 billion aliens living all over the world. In fact you are probably one of them. And not just any alien, but a nonresident alien, maybe even a nonresident alien spouse. “But I am Australian and live in Australia,” you might object. “I have never been out of…
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US 1 | US Tax While Living in Australia
Are you or your client a US American living in Australia? There are over 100,000 US Americans living down under. Not a huge number compared to other nationalities migrating to Australia, but still a big group and rapidly increasing. As a US citizen or resident alien, the US will tax your…
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ABOUT THIS SHOW
The podcast for Australian accountants with US clients. Find the experts and information you need to optimise your clients’ cross-border tax position. Help your clients invest or expand from Australia into the US and from the US into Australia.
Hosted on Acast. See acast.com/privacy for more information.
HOSTED BY
Heide Robson
CATEGORIES
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Frequently Asked Questions
How many episodes does US Tax have?
US Tax currently has 33 episodes available on PodParley. New episodes are automatically indexed when they're published to the podcast feed.
What is US Tax about?
The podcast for Australian accountants with US clients. Find the experts and information you need to optimise your clients’ cross-border tax position. Help your clients invest or expand from Australia into the US and from the US into Australia. Hosted on Acast. See acast.com/privacy for more...
How often does US Tax release new episodes?
US Tax has 33 episodes. Check the episode list to see recent publication dates and frequency.
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You can listen to US Tax on PodParley by clicking any episode. We provide an embedded audio player for direct listening, and you can also subscribe via your preferred podcast app using the RSS feed.
Who hosts US Tax?
US Tax is created and hosted by Heide Robson.
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