South Carolina · United StatesWONE Global Partner · United States
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United States × Tax & International Structuring
Tax & International Structuring in the United States
Tax and structuring for businesses, investments and deals that cross borders. In the United States, that means local law, local regulators and local practice, handled by a qualified professional who practises there.
Who handles this work
On request
WONE Global can find the right Tax & International Structuring professional in the United States for you.
No WONE Global Partner holds this yet. Send us your requirement: WONE Global confirms whether a vetted Associate firm can act, tells you who it is and checks for conflicts before any work begins.
Bring a requirement →United States at a glanceNorth America
New York · Tuesday 3 November
15:00
Local time
- Currency
- USD
- Working week
- Monday – Friday
- Commercial centres
- New York · California · Texas · Florida
- Dialling code
- +1
- Region
- North America
What the rules say in the United States
Tax & International Structuring, the essentials
From the United States market guide: the points that matter most for tax & international structuring, each with the source it was checked against.
Full guide · Source-checked research100% of statements checked against a source127 checked against an official source2 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed
An applicant for an employer identification number (EIN) whose principal place of business is outside the US can apply by phone, fax or mail; online application is available where the principal place of business is in the US.
Federal (IRS). The IRS limits applicants to one EIN application per day. International applicant phone line: +1 267-941-1099.Internal Revenue Service (IRS) · checked 2026-10-18US corporations figure federal income tax by multiplying taxable income by 21%.
Federal corporate income tax. State and local corporate income or franchise taxes are additional and vary by state.Internal Revenue Service (IRS) · checked 2026-10-18For tax years beginning after 2022, section 55 of the Internal Revenue Code imposes a corporate alternative minimum tax (CAMT) based on the adjusted financial statement income of applicable corporations, determined on Form 4626.
Federal. Applies only to applicable corporations; the size threshold was not confirmed on the page opened.Internal Revenue Service (IRS) · checked 2026-10-18A corporation must generally file its federal income tax return (Form 1120) by the 15th day of the 4th month after the end of its tax year.
Federal. A corporation with a fiscal year ending 30 June files by the 15th day of the 3rd month after year end.Internal Revenue Service (IRS) · checked 2026-10-18The 2025 Instructions for Form 1120 reflect changes made by Public Law 119-21, commonly known as the One Big Beautiful Bill Act.
Federal. Applies to 2025 calendar-year returns and fiscal years beginning in 2025.Internal Revenue Service (IRS) · checked 2026-10-18Income of a foreign corporation that is effectively connected with a US trade or business is taxed at the same rates as income of a US corporation, after allowed deductions, and is reported on Form 1120-F.
Federal. Applies to foreign corporations operating in the US directly (for example through a branch); also covers US-source FDAP income.Internal Revenue Service (IRS) · checked 2026-10-18A foreign corporation with a US office or place of business must file Form 1120-F by the 15th day of the 4th month after its tax year ends; one without a US office or place of business has until the 15th day of the 6th month.
Federal.Internal Revenue Service (IRS) · checked 2026-10-18Fixed, determinable, annual or periodical (FDAP) income from US sources paid to a foreign person, such as interest, dividends, rents and royalties, is taxed at 30% or a lower treaty rate, with no deductions or netting allowed.
Federal. Usually collected by withholding at source. A reduced rate or exemption may apply under the Internal Revenue Code or a tax treaty.Internal Revenue Service (IRS) · checked 2026-10-18
Read the full guide: Entry, investment and company formation · Tax, accounting and reporting · Employment, payroll and mobility · Licensing, sector rules and property · Banking, payments and repatriation
Scope
What the service covers here
- 01Review the proposed cross-border structure
- 02Identify direct and indirect tax exposures
- 03Consider withholding, treaty and transfer-pricing issues
- 04Coordinate implementation across the relevant jurisdictions
Key questions
What we will work through with you
- What needs to be decided before tax & international structuring work starts?
- Who is professionally responsible in each country?
- Which other work, such as tax or employment, must happen at the same time?
- What information and decisions are needed from the business?
If your work involves another country or another area of expertise, WONE Global brings in the right professional and keeps all advisers informed.
WONE Global Partners in the United States
Professionals working here
No named lead for Tax & International Structuring yet — these WONE Global professionals already work in the United States and can bring the right local colleague in.
South Carolina · United StatesAlso in the United States
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Cases
What clients bring to Tax & International Structuring
The cases this service leads or joins, each with what is at stake, how WONE Global handles it and who handles it in the United States.
Urgent We've received a tax notice from another country. Do we have to pay?Tax assessments, disputes & managementUrgent We sell online to customers abroad. Do we have to register for their VAT or GST?Tax assessments, disputes & managementUrgent Tax was deducted abroad and again at home. Can we get it back?Payments, FX, digital assets & treasuryUrgent The tax authority wants our transfer pricing documentation. We don't have any.International tax planning & transfer pricingWhat tax filings do we have to make in each country, and when?Tax assessments, disputes & managementHow should we price and invoice customers abroad so we actually get paid?Contracts, commercial disputes & collectionsAt what point do our sales abroad mean we need a local company?International tax planning & transfer pricingShould we reorganise how our regional business is run?International tax planning & transfer pricingCan we centralise finance, HR or IT in one country?International tax planning & transfer pricingHow do we move cash between our companies in different countries?Payments, FX, digital assets & treasury
WONE Global Intelligence
Ask about tax & international structuring in the United States
Ask in your own words. Answers come from WONE Global's checked records, with every source shown, and end with the named Partner who can act. Go deeper on any point, or build a decision file.
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