CPA - medium firm
CPA - large firm
Enrolled Agent
Foreign entities can be subjected to United States income tax requirements when their income is effectively connected to the United States. Such entities can create tax and reporting requirements for United States-based stakeholders as well. An often overlooked—and unfortunately, often oversimplified consideration—is how the foreign entity is classified for United States tax purposes. Critically, the United States maintains its own distinct rules for the classification of foreign entities, and those rules are in no way impacted by how the entity is taxed in its home jurisdiction! Join this webinar for an in-depth discussion of the relevant considerations in this context, including tax ramifications for foreign trusts, foreign corporations, and foreign pass-through entities.
Learning Objectives:
- Identify how foreign entities can be subjected to United States income tax requirements
- Determine how foreign entities can create tax and reporting requirements for United States-based stakeholders
- Recall how a foreign entity is classified for tax purposes
Patrick McCormick, JD, LLM
Rimon PC
Partner
[email protected]
(215) 630-0861
Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.
Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.
Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.
Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
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