Season 2 Episode 02:

Coming to America (Part 2): Key U.S. Tax Considerations

Entering the U.S. market involves far more than forming an entity- it requires thoughtful planning across incentives, compliance, and exit strategy. In this episode, Chris Klug and Gina Lee unpack the federal, state, and cross-border tax considerations non-U.S. businesses must address once U.S. operations begin.

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In this episode of the Under the Basswood Tree podcast, Chris Klug and Gina Lee continue the Coming to America series with a focused look at the U.S. tax considerations non-U.S. businesses face once operations begin. They walk through key issues to evaluate- from federal and state incentives to transfer pricing, treaty benefits, real estate considerations, and exit planning.

The conversation highlights why viewing U.S. expansion through a global lens and planning early can help avoid costly missteps while positioning the business for long-term, sustainable growth.

Listen to Part 1 of the Coming to America series here.

Episode highlights:

  • How federal tax incentives including R&D credits, bonus depreciation, and Section 179 factor into U.S. operating decisions

  • Why domestic R&D expensing under OBBBA creates meaningful opportunities for eligible foreign-owned businesses

  • Common transfer pricing pitfalls, why documentation matters, and how the arm’s-length standard is applied

  • How income tax treaties allocate taxing rights, reduce double taxation, and shift the analysis to permanent establishment

  • The impact of FIRPTA on foreign owners of U.S. real estate and why withholding can create cash-flow issues

  • Why state and local taxes often apply even when federal tax does not, including income, sales, and economic nexus rules

  • How exit planning – stock sales, asset sales, dividends, or liquidation – must be evaluated on a global, not single-country, basis

Host: Chris Klug

Chris is a trusted attorney with extensive experience in taxation, corporate planning, mergers and acquisitions, and estate planning. He guides clients through complex tax matters to deliver practical solutions.

Host: Gina Lee

Gina Lee is your trusted guide for U.S. tax law, corporate compliance, and estate planning, providing personalized, strategic counsel to help achieve your financial and personal goals with confidence.

If this episode resonates with what you’re working through, contact info@basswoodcounsel.com. We’ll help you bring clarity to the key decisions, risks, and priorities, with the right support across our complementary practice areas.

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