Investing into the US

Structuring investment into the United States entails a number of considerations, and can be tricky.

Because of the high US taxes and withholding taxes that usually apply to returns on inbound investment, structures need to take advantage of US domestic opportunities that permit lower US tax.

It’s also important to take full advantage of reductions in withholding tax under applicable US Tax Treaties. This entails compliance with the Limitation On Benefits (LOB) requirements that apply under most Treaties.

Dealing with LOB requires skill and experience, especially where the investors reside in more than one country, or in a country with unfavorable Treaty provisions.

In addition to LOB, intermediate holding structures need to satisfy additional requirements, including intermediate country tax efficiency, the existence of suitable infrastructure and substance in intermediate countries, and in some cases, acceptable intermediate country perception.

We have significant experience with inbound investment structures. We work with select non-US firms to ensure satisfaction of the non-US components.