Entering the U.S. market raises legal and tax questions at the same time: which entity to use, how to hold and fund it, and what each country will tax. We help Chinese and other foreign businesses — and U.S. companies working with them — set up structures that work commercially and hold up over time.
Scope of representation
- U.S. market entry and entity structure (LLC, corporation, branch)
- Cross-border investment routes, holding structures and funding
- International tax planning, treaty issues and transfer-pricing support
- U.S. reporting for foreign-owned companies and foreign entities
- Cross-border contracts, supply-chain arrangements and long-term compliance
Market entry and entity design
A U.S. expansion involves more than forming a company. We start with the business model — customers, operations, people, ownership, financing and exit or succession goals — and then compare entity and ownership options, so the structure fits the intended activity rather than a generic formation package.
Investment, cash flow and transfer pricing
Capital contributions, intercompany arrangements, compensation, distributions and asset ownership raise both legal and tax questions. We map these flows, review the documents, and coordinate with accountants and transfer-pricing specialists so that contracts, functions, records and tax positions align.
IRS and state tax notices
For an IRS or state notice, we first review the tax periods, prior filings, the stated issue and the response instructions before proposing an engagement.
How a matter proceeds
- Understand the business. Owners, operations, customers, cash flow and goals in each country.
- Compare structures. Liability, tax, reporting and practical trade-offs of each option.
- Implement and maintain. Formation, agreements, registrations and a compliance calendar.
Timing and fees
Timing depends on the notice, the agency or court, and the facts. Response dates stated in a notice are reviewed individually as soon as we receive it. Scope, fees and any deposit are discussed before we are engaged and confirmed in a written engagement letter.
Documents for an initial review
- Current entity documents and an ownership or group chart
- Business plan, investment amounts and proposed cash flows
- Tax returns, government notices and prior professional advice
- Key contracts and details of U.S. personnel, assets and activities
E-mail copies to info@attorneywu.com with the subject “Your name – short description”. Please do not send documents through the chat or the booking form.
Frequently asked questions: tax controversy, international reporting and pre-immigration planning
Who must file an FBAR, and when is it due?
A U.S. person (including green-card holders and tax residents) whose foreign financial accounts total more than US$10,000 at any time during the year must file FinCEN Form 114 (FBAR). It is due April 15, with an automatic extension to October 15. Penalties for non-willful and willful failures differ greatly, so late filers should get advice before filing.
Why plan taxes before moving to the U.S. or getting a green card?
Once you become a U.S. tax resident, the U.S. generally taxes your worldwide income and requires reporting of foreign accounts, companies and trusts. Steps taken before residency — such as reviewing the basis of appreciated assets, timing income, restructuring foreign companies, and making gifts or trusts — can be far more effective than fixes afterward.
I received an IRS Notice of Deficiency. What is the deadline?
A Notice of Deficiency (the “90-day letter”) generally gives 90 days from its date to petition the U.S. Tax Court — 150 days if it is addressed to a person outside the United States. Filing on time lets you dispute the tax before paying it. The deadline is strict, so contact counsel as soon as the letter arrives.
General information only, not legal advice. Book a consultation for advice on your situation.
