Tax Services
US Inbound Tax
Tax structuring for foreign companies entering the US
Navigate US Taxation with Local Expertise and Global Insight
Miami-based tax planning and compliance for foreign investors, nonresident aliens, and international corporations, structuring US operations so income is properly classified and every treaty benefit is claimed.
Treaty-driven structuring that reduces withholding and minimizes the rate on Effectively Connected Income.
Core Directives
- Treaty optimization
- ECI structuring
- Full compliance coverage
Ready when you are
Get startedOperational Milestones
Classify
We classify every stream of US-source income as ECI or FDAP to determine the correct tax treatment, then review applicable treaties for reduced rates, exemptions, and credits.
Structure
We advise on entity selection, operational setup, and investment structures that minimize your overall US tax burden.
File
Precise, timely filing of all required returns, including 1040-NR, 5472, and 1120-F, with year-round monitoring of regulatory and treaty changes.
Included Services & Outcomes
30% Withholding Without a Treaty Plan
FDAP income, including dividends, interest, rents, and royalties, is subject to a flat 30% withholding rate unless reduced by an applicable tax treaty.
Questions
US Inbound Tax FAQ
What is the difference between ECI and FDAP income?
Effectively Connected Income (ECI) is income from an active US trade or business, taxed at graduated rates on a net basis after deductions. FDAP income, such as dividends, interest, rents, and royalties, is taxed at a flat 30% gross rate, withheld at source, unless a treaty applies.
Can tax treaties reduce my US withholding rate?
Yes. Many US tax treaties reduce or eliminate the 30% statutory withholding rate on FDAP income. The specific rate depends on your country of residence and the type of income. We analyze every applicable treaty provision to ensure you receive the maximum benefit.
What is Form 5472 and do I need to file it?
Form 5472 is required for any foreign-owned US corporation (25% or more foreign ownership) that has reportable transactions with related foreign parties. Failure to file carries a minimum $25,000 penalty per form, making timely and accurate filing critical.
Do I need a US tax ID to file?
Yes. Nonresident aliens generally need an Individual Taxpayer Identification Number (ITIN), and foreign corporations need an Employer Identification Number (EIN). We assist with all tax ID applications as part of our onboarding process.
How long does US inbound structuring take?
Initial entity formation and EIN registration closes in 2 to 3 weeks. Full operational setup, including treaty analysis, banking, transfer pricing, and compliance calendar, typically takes 6 to 10 weeks. Timelines flex with immigration or investment deadlines.
Put SMAART Tax on your us inbound tax
Book a free consultation. We'll review your situation, quote a fixed fee, and show you exactly what we'd do differently.