Rives CPA worldwide clients

Change in process to obtain an EIN affects non-residents

IRS news release IR-2019-58 announced a change in procedures for obtaining an Employer Identification Number (EIN )for a US business entity.  This will impact non-residents with US based entities. Beginning May 13, 2019, only individuals with a Social Security Number (SSN) or International Tax Identification Number (ITIN) will be able to request an EIN.  The Read more about Change in process to obtain an EIN affects non-residents[…]

What is the best state to incorporate in for a foreign startup?

What is the best state to incorporate in for a foreign startup? Answer by Wray Rives: There are so many variables, all I can do is give you some general ideas about foreign nonresident owners of US entities and what states make “tax sense” for the non-resident owners. First I assume you that you want Read more about What is the best state to incorporate in for a foreign startup?[…]

Transfer pricing of tangible goods between controlled businesses

The Internal Revenue Service has adopted specific regulations to govern how related businesses should determine pricing and allocate profits among related businesses.  This is of particular interest to US businesses that are controlled by non-US taxpayers either directly or through related non-US businesses and which sell goods sourced by the non-US taxpayers into the US Read more about Transfer pricing of tangible goods between controlled businesses[…]

US Taxation of Nonresident Alien Income

US taxation of nonresident alien income can be a complicated topic.  The source of income is one of the primary factors that determines if a nonresident alien owes US tax on income from US sources.  The following table will summarize the sourcing rules for income that may or may not be subject to US Federal Read more about US Taxation of Nonresident Alien Income[…]