As of January 1 2017 there were new rules in place for foreign owners of US LLCs that were treated as disregarded entities (DREs) for US tax purposes. What I want to do is highlight where this may occur in peoples situations and structures and why it is important to comply (HINT: $10,000 penalty for non-compliance).
Just over a week ago I had the privilege to spend a few days with the many colleagues we work alongside in our Nexia network at the international tax conference in Cologne.
As part of the conference I was asked to put together some case studies and work alongside my colleagues Julian Hedley, Pablo Gomez-Acebo and Chris Leenders with regards to the international tax consequences that are unique to sportspersons and entertainers. Given that much of the work was already done I thought it worthwhile to put together some of what we went over starting with the basics and looking to elaborate on these items later down the line.