Badyal Law Blog
Legal Insights and News409A – A Brief Overview
Section 409A of the Internal Revenue Code imposes a complicated set of rules and requirements upon any “nonqualified deferred compensation plan.” Failure to comply with the requirements of Section 409A will result in an additional federal income tax of 20%. This 20%...
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Structuring a Foreign Manufacturer’s U.S. Sales Office
International Tax Structuring for Foreign Manufacturer's U.S. Sales Office. (1) In the absence of a tax treaty, a foreign corporation is subject to U.S. federal income taxes if it has gross income that is “effectively connected” with the conduct of a U.S. trade...
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U.S. Taxation of Inbound International E-Commerce
U.S. Taxation of Inbound International E-Commerce The purpose of this article is to provide a brief and general overview of the tax implications for a foreign entity that sells its goods into the United States over the Internet. Due to the complexity of the rules in...
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