Tag Archives: effectively connected income

Bye Bye Brazil! – Tax Planning Considerations for Brazilian Investment in the United States: Part II – Additional Income Tax Considerations

07 Mar
Brasão de Armas da Marinha do Brasil - Income Tax

I have mentioned in prior articles my affiliation with the South Florida law firm Osborne and Osborne, PA in Boca Raton. Back to the beginning! Boca Raton is where I started right out of the Army in 1987. I moved to Miami for law school. Even though I have been living in New England and […]

Offshore Investment into the United States

17 Feb
The Naval Temple at The Kymin Monmouth - Offshore Investment

Sophisticated tax structuring is generally involved in the Investment activities of foreign private and sovereign investors in U.S. private equity and real estate investments, that generate effectively connected income to a U.S. trade or business (ECI). The focus of this structuring generally accomplishes several important tax and non-tax objectives. Re-characterization of income otherwise it’s subject […]