Insights: Events Tax Concerns of Foreign Persons Investing in the United States – Active Investments

PLI’s Basics of International Taxation

Wednesday, July 24, 2024

This session will provide an overview of the U.S. taxation of foreign persons, both generally and as it relates to different types of income from active investments. After completing this session, participants will be able to:

  •  Use the two-part U.S. trade or business (“USTB”) test to determine when a foreign person is subject to U.S. tax on business income
  • Determine when income is considered to be effectively connected (“ECI”) to a USTB, applying recent guidance including the YA Global decision
  • Calculate base erosion and anti-abuse tax (“BEAT”)

Event Details

Wednesday, July 24, 2024


PLI New York
1177 Avenue of the Americas, New York, New York 10036

9:00 a.m. - 10:30 a.m.
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