Using Irish Treaty Funds To Avoid US Taxes In Direct Lending

Private debt funds raised more than $100 billion for the fourth consecutive year in 2018,1 and reached their highest level of fundraising on record during the first half of 2019.2

However, U.S. tax law potentially hinders U.S. managers from sponsoring direct lending funds that have foreign investors: The IRS has asserted that foreign funds managed from within the U.S. and make loans directly to borrowers may be engaged in a U.S. trade or business and subject […]

By | October 12th, 2019 ||

Do You Have To Withhold 30% On Payments To A Non-U.S. Independent Contractor?

In the global village where we live, U.S. companies are not limited to U.S. individuals when searching for the right service provider. U.S. companies often hire non-U.S. individuals for the job. These individuals include non-U.S. citizens living outside the U.S., who generally don’t need to be present in the U.S. to provide services, and non-U.S. citizens who are temporarily present in the U.S. on an appropriate visa.

Generally, temporary immigrants will be considered U.S. tax […]

By | October 5th, 2019 ||

Top 5 Modern Tax Challenges For Digital Health Companies

Digital health companies comprise a broad, fast-growing sector of businesses that deploy technology in order to improve users’ health and wellness. Digital health technologies span a wide gamut and include telemedicine, wearable health devices, electronic medical record companies (EHRs or EMRs), mobile health and wellness apps (mHealth), and cost-reducing artificial intelligence deployed by pharmaceutical companies.

These disruptive technologies are revolutionizing the delivery of health care products and services to the full range of participants in […]

By | October 1st, 2019 ||