(Between US and non-US parties)
Services between US and non-US parties entails planning for the tax consequences that will arise both to the party rendering the service and receiving the service.
Where the party rendering the services is related to the party receiving the services, provided the norms of transfer pricing are observed, the cross-border nature of these transactions lend themselves to tax arbitrage.
Where a non-US party renders services to US customers, one of the considerations is whether a US entity should be formed (see Forming a US Entity?). Similarly, where a US party renders services to non-US customers, consideration needs to be given to whether a non-US entity should be formed (see Non-US Entity?).
If the non-US party resides or was formed in a country with which the US has a tax treaty, this cross-border rendering of services often gives rise to questions under the treaty (see Tax Treaty Question?).
Whether the services are rendered in the US or in another country, in many cases there will be a US tax compliance requirement (see Tax Return Question?).
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