top of page

U.S. Tax Attorney

U.S. Tax Attorney

U.S. INTERNATIONAL TAXATION

Introduction to U.S. International Taxation

Navigating U.S. and foreign tax rules is one of the most challenging aspects of cross-border business and personal finance. As a tax attorney focused on international matters, I help clients simplify this landscape. My work centers on U.S. tax liability for foreign persons, the effective use of tax treaties, and the compliance obligations tied to U.S. withholding and filing. Whether you are a foreign company investing in the U.S., a nonresident earning U.S.-source income, or an international enterprise seeking compliance support, I turn complex rules into clear, practical strategies that reduce risk and improve after-tax outcomes.

I also advise on U.S. anti-deferral regimes – including Subpart F, GILTI/NCTI, and PFIC rules – and develop strategies to minimize exposure while maximizing the benefits of foreign tax credits and deductions. My guidance includes proper allocation of foreign expenses, identification of tax-arbitrage risks, and comprehensive planning and compliance support. I provide proactive, detail-driven representation to help you meet the demands of global tax compliance with confidence.

MY PRACTICES

U.S. Tax Returns & Disclosures

Foreign Tax Credit & Foreign Expenses

Foreign Income of U.S. Persons

U.S. Income of Foreign Persons

Tax Arbitrage
& Tax Treaties

Foreign Income of U.S. Persons (Outbound)

The U.S. federal income tax system is built upon the Worldwide Taxation Principle, under which U.S. citizens, residents, and domestic corporations are subject to tax on all income – regardless of where it is earned. Unlike jurisdictions that employ a territorial system, the United States asserts global taxing authority over its taxpayers. This authority originates from the 16th Amendment, which permits Congress to tax income “from whatever source derived,” and is codified in Internal Revenue Code (IRC) § 61(a), which defines gross income as “all income from whatever source derived.” This expansive jurisdiction was definitively upheld by the Supreme Court in Cook v. Tait, 265 U.S. 47 (1924), which confirmed that the U.S. may tax its citizens on foreign-source income based on the enduring relationship between the taxpayer and the United States.

Because such income is often taxed again by the foreign jurisdiction, the U.S. seeks to mitigate double taxation primarily through the Foreign Tax Credit (IRC §§ 901–909) and other tax breaks (foreign earned income & housing exclusion, etc.). However, the Worldwide Taxation Principle also creates a second challenge: the possibility of indefinite tax deferral if income is retained inside foreign entities rather than distributed to U.S. owners. This challenge is addressed by U.S tax authorities through a series of sophisticated anti-deferral regimes.

Anti-Deferral Regimes: Limiting Offshore Tax Deferral. To prevent U.S. taxpayers from postponing U.S. tax by accumulating income in foreign corporations, the Internal Revenue Code establishes several anti-deferral regimes that compel current inclusion of certain foreign-source income. These rules function as guardrails within the Worldwide Taxation framework, ensuring that offshore structures do not distort U.S. taxing jurisdiction.

Subpart F: The Foundational Anti-Deferral Regime (IRC §§ 951–965). Enacted in 1962, Subpart F was the first comprehensive U.S. response to the use of foreign holding companies to shelter passive or highly mobile income. A foreign corporation is classified as a Controlled Foreign Corporation (CFC) if more than 50% of its vote or value is owned by U.S. shareholders (as defined in IRC § 951(b)).

When CFC status is met, U.S. shareholders must include their pro-rata share of “Subpart F income” currently, without regard to actual distributions (IRC § 951(a)). Subpart F income typically includes:

Foreign Personal Holding Company Income (FPHCI) – interest, dividends, rents, royalties (IRC § 954(c));
Foreign Base Company Sales Income (FBCSI) – sales structured through low-substance foreign affiliates (IRC § 954(d));
Foreign Base Company Services Income (FBCSvI) – services performed for related parties outside the CFC’s country of organization (IRC § 954(e));
Insurance and other specialized categories recognized as “movable” income.

These forced inclusions—supported by detailed rules in Treas. Reg. §§ 1.951–1.965 – eliminate the ability to defer U.S. tax through offshore accumulation of passive or mobile income.

From GILTI to the Modern Net CFC Tested Income Framework (IRC §§ 951A, 250). The Tax Cuts and Jobs Act of 2017 (TCJA) introduced Global Intangible Low-Taxed Income (GILTI) under IRC § 951A, representing the most significant expansion of U.S. anti-deferral policy since Subpart F. Originally, GILTI applied a minimum tax to a CFC’s residual profits in excess of a 10% deemed return on its qualified tangible business assets, known as Qualified Business Asset Investment (QBAI), with the 10% return termed the Deemed Tangible Income Return (DTIR).

Recent legislative reforms and regulations have structurally reconfigured this regime. The modern approach – commonly referred to as Net CFC Tested Income (NCTI) – eliminates the DTIR exclusion, meaning that nearly all of a CFC’s tested income is subject to mandatory current inclusion for U.S. shareholders.

This shift has three major effects:

Broadens the U.S. tax base to include nearly all CFC operating profits.
Removes the incentive to shift tangible assets offshore.
Transforms GILTI from a quasi-intangible tax into a comprehensive anti-deferral regime.

Corporate U.S. shareholders may still benefit from the § 250 deduction and related foreign tax credit rules under IRC §§ 960–904, while individual shareholders may require planning strategies such as a § 962 election.

The PFIC Regime: Anti-Deferral Without U.S. Control (IRC §§ 1291–1298)

The Passive Foreign Investment Company (PFIC) regime operates independently of CFC status and applies even when a U.S. shareholder owns a small minority interest in a foreign corporation. Under IRC § 1297, a foreign corporation is a PFIC if it meets either:

the 75% passive income test, or
the 50% passive asset test.

When no protective election is made – such as a Qualified Electing Fund (QEF) election under IRC § 1295 or a Mark-to-Market election under IRC § 1296 – U.S. taxpayers face:

Taxation of “excess distributions” and gains at the highest rate, plus
An interest charge designed to replicate the lost time-value of deferred tax (IRC § 1291(c)).

Compliance requires annual filing of Form 8621, often for each PFIC investment. Importantly, when a foreign corporation is both a CFC and a PFIC with respect to the same U.S. shareholder, the CFC rules (Subpart F and NCTI) generally displace the PFIC regime (Treas. Reg. § 1.1291-1(b)(3)(ii)), preventing duplicative anti-deferral taxation.

Navigating U.S. international tax rules – Subpart F, GILTI/NCTI, PFIC, and the Foreign Tax Credit system – can be complex and high-stakes. I help individuals, businesses, and investors simplify these challenges and make informed decisions.

For Clients

Identify and manage CFC, Subpart F, and GILTI/NCTI exposures
Assess PFIC risks and prepare required filings
Optimize foreign tax credits and reporting obligations
Provide strategic planning for offshore investments and entity structures

For Tax Professionals

Deliver legal opinions and technical guidance on cross-border matters
Review complex international filings and compliance positions
Support firms handling global clients, M&A, and multijurisdictional issues

I turn complex rules into clear, actionable strategies to reduce risk, ensure compliance, and protect your global investments.

My Assistance

U.S. Income of Foreign Persons (Inbound)

U.S. Taxation of Foreign Persons: Inbound Rules for Individuals and Corporations

Section I — Overview of the U.S. Inbound Tax Framework. The United States imposes a specialized set of income tax rules on foreign individuals and foreign corporations. These rules determine whether a foreign person is subject to U.S. tax, how income is sourced, and when foreign-source income can nevertheless be taxed by the United States. Although the Internal Revenue Code provides the statutory foundation, the practical operation of these rules comes almost entirely from the Treasury Regulations – especially 26 CFR §§ 1.864-1 through 1.864-7, 1.871-1, 1.881-1, and 1.882-2. These regulations establish the meaning of a U.S. trade or business, outline the tests for effectively connected income (ECI), and define the circumstances under which foreign-source income is attributed to U.S. commercial activity.

Understanding U.S. inbound taxation requires appreciation of two concepts: the distinction between U.S.-source and foreign-source income, and the classification of income as either effectively connected with a U.S. trade or business or not so connected. Every foreign taxpayer is analyzed through this dual lens to determine the correct U.S. tax outcome.

Section II — Nonresident Alien Individuals. The taxation of nonresident alien individuals (NRAs) is governed by IRC §§ 871(a)–(b) and 26 CFR § 1.871-1(a). In general, NRAs are taxed only on U.S.-source income that is not effectively connected with a U.S. trade or business, and on income – regardless of where earned – that is effectively connected with such a business. U.S.-source non-ECI income, often referred to as FDAP income (“fixed or determinable annual or periodical”), includes passive items such as interest, dividends, rents, and royalties, and is typically taxed at a flat 30 percent rate under IRC § 871(a) unless reduced by treaty. The sourcing of these items is defined by the detailed rules in 26 CFR §§ 1.861-2 through 1.861-7.

Income is treated as effectively connected with the conduct of a U.S. trade or business when it satisfies the qualitative standards contained in 26 CFR §§ 1.864-3 through 1.864-7. These regulations apply a series of tests – the asset-use test, the business-activities test, and the U.S.-office attribution rules – to determine whether income has the necessary nexus to U.S. commercial activity. Effectively connected income is taxed on a net basis under IRC § 871(b), allowing deductions that are properly allocable to the income.

A limited set of foreign-source income items may be drawn into the NRA tax base under IRC § 864(c)(4), but only when the income is attributable to a U.S. office or other fixed place of business. This narrow extension applies mainly to royalties tied to intangible property exploited through U.S. activities, certain financial income arising from active U.S. banking or financing operations, and foreign sales of inventory attributable to a U.S. sales office. These foreign-source attribution rules apply far more modestly to NRAs than to foreign corporations, reflecting the much narrower congressional intent to tax individuals on foreign activity.

Section III — Foreign Corporations. Foreign corporations face a more expansive and complex inbound tax regime. Treasury Regulations divide them into two categories under 26 CFR § 1.881-1(a): corporations that are not engaged in a U.S. trade or business during the tax year, and corporations that are engaged in a U.S. trade or business at any point. A corporation that is not engaged in a U.S. trade or business is generally taxable only on U.S.-source FDAP income and on the items listed in IRC § 881(a). However, 26 CFR § 1.882-2 provides that certain U.S.-source items may be treated as ECI even without active U.S. business operations, most notably where a corporation elects under IRC § 882(d) to treat U.S. real property income as effectively connected in order to claim allowable deductions.

The tax base expands considerably once a corporation is deemed engaged in a U.S. trade or business at any time during the year. In such cases, IRC § 882(a) and 26 CFR § 1.882-1 tax the corporation on all income, from any source, that is effectively connected with its U.S. activities. This “worldwide ECI” principle is a defining difference between the corporate and individual regimes. Foreign corporations also remain taxable on U.S.-source income that is not effectively connected with their U.S. business, including FDAP items and other income specified in IRC § 881(a). Moreover, the deemed-ECI rules of § 1.882-2 continue to enlarge the corporate tax base in specific circumstances.

Section IV — The Concept of a U.S. Trade or Business and the Central Role of ECI. A pivotal concept in both the individual and corporate regimes is the definition of “engaged in a trade or business within the United States,” articulated in 26 CFR § 1.864-3. The regulation provides that the performance of personal services in the United States generally creates engagement in a U.S. trade or business. At the same time, it excludes certain activities entirely, most prominently trading in stocks, securities, or commodities for one’s own account. These safe harbors, codified in § 1.864-3(c) and (d), are critical for investment funds, private investors, and financial structures seeking to avoid unintended ECI exposure.

The classification of income as effectively connected is a detailed regulatory inquiry. The framework established by 26 CFR §§ 1.864-3 through 1.864-7 defines when income bears a sufficient nexus to U.S. activity, when foreign-source income must be attributed to a U.S. office, and how the qualitative connection between income and the taxpayer’s U.S. operations is measured. This regulatory architecture has far broader consequences for foreign corporations than for nonresident individuals, which explains the markedly different tax outcomes faced by each class of taxpayer.

Foreign persons with income or commercial relationships involving the United States must analyze their activities carefully under these rules. The distinction between FDAP and ECI, the presence or absence of a U.S. trade or business, and the application of attribution rules can materially alter tax liabilities, withholding obligations, and treaty positions. My practice advises individuals, corporations, family offices, financial institutions, and investment structures on the full spectrum of inbound U.S. tax issues, from ECI classification and structuring to audit defense and cross-border compliance. If your U.S. activities raise questions under these rules, I can assist in assessing your exposure and developing a clear, defensible, and optimized position.

The intricate framework of U.S. inbound taxation—governed by the statutory distinction between Nonresident Aliensand Foreign Corporations, the pivotal concept of a U.S. Trade or Business, and the resultant classifications of FDAPversus ECI—creates a critical need for expert guidance. Misclassification or failure to file can lead to unexpected tax liabilities, severe penalties, and complex disputes with the Internal Revenue Service (IRS).

My practice specializes in navigating this complex regulatory architecture to provide foreign individuals, corporations, and investment structures with clear, defensible, and optimized U.S. tax positions.

I offer advisory and compliance services across the full spectrum of inbound U.S. tax matters, including:

ECI and USTB Analysis: Rigorous assessment of commercial activities to determine the presence of a U.S. Trade or Business and proper classification of income as Effectively Connected Income (ECI), including utilization of statutory safe harbors (e.g., trading in stocks or securities for one's own account).
Tax Treaty Application: Analyzing eligibility for benefits, including assessment under the Limitation on Benefits (LOB) provisions, to claim reduced withholding rates and protection from local tax exposure (e.g., Permanent Establishment rules).
Entity Classification and Structuring: Advising on the optimal use of legal entities for U.S. investments (e.g., determining whether to elect for U.S. real property income to be treated as ECI under IRC § 882(d)).
Withholding and Reporting Compliance: Assisting payors and recipients with U.S. withholding tax obligations (e.g., Forms W-8BEN, W-8BEN-E, W-8ECI) and ensuring timely, accurate annual compliance filings (e.g., Forms 1120-F, 1040-NR).
IRS Audit Defense and Dispute Resolution: Representing foreign taxpayers in examinations and disputes related to ECI, USTB, and the application of treaty benefits.

If your income or commercial relationships involving the United States raise questions under these critical inbound tax rules, I can assist in assessing your exposure and developing a clear, defensible, and optimized compliance strategy. Contact me today to ensure your U.S. activities are structured for success.

Professional Assistance in U.S. Inbound Taxation

U.S. Tax Returns & Disclosures

The U.S. tax system is among the most complex in the world, especially for individuals and corporations with international connections. U.S. taxation is based on citizenship and residency, meaning U.S. citizens and resident aliens are taxed on their worldwide income regardless of where they live or earn money. Nonresident aliens, by contrast, are generally taxed only on income sourced in the United States or effectively connected with a U.S. trade or business (ECI). Compliance requires filing the appropriate income tax returns along with numerous disclosure forms for foreign income, assets, trusts, and entities. Failure to comply can result in significant penalties. This guide provides a detailed roadmap of filing requirements, relief mechanisms, and mandatory disclosure obligations.

Individual Taxpayers: U.S. Residents and Citizens. U.S. citizens and resident aliens are required to report their worldwide income on Form 1040, including wages, interest, dividends, capital gains, self-employment income, rental income, and foreign-source income. Generally, the Form 1040 is due on April 15, with an optional extension to October 15 through Form 4868. For U.S. citizens and residents living abroad, an automatic two-month extension is granted, making their initial deadline June 15, with the possibility of extending further to October 15 using Form 4868.

Individuals living and working outside the United States have several mechanisms to mitigate double taxation on foreign income. First, the Foreign Earned Income Exclusion (FEIE) under IRC §911 allows eligible taxpayers to exclude a statutory amount of foreign earned income and claim a foreign housing exclusion or deduction using Form 2555. It is important to note that the FEIE does not reduce self-employment tax, and only income earned abroad qualifies. Passive or U.S.-source income cannot be excluded.

Second, taxpayers may claim a Foreign Tax Credit (FTC) on Form 1116 for income taxes paid to foreign jurisdictions under IRC §901. The FTC provides a dollar-for-dollar offset against U.S. tax liability for foreign taxes paid but cannot be claimed on income already excluded under the FEIE. The credit is generally limited to the portion of U.S. tax attributable to foreign-source income.

Additionally, if a taxpayer relies on a tax treaty to override or modify U.S. tax law – for example, claiming a reduced tax rate on certain types of income – they must file Form 8833, Treaty-Based Return Position Disclosure. Failure to file Form 8833 when required can trigger penalties under IRC §6662A. For taxpayers with prior non-compliance, programs such as the Streamlined Filing Compliance Procedures or the Offshore Voluntary Disclosure Program (OVDP) may provide reduced penalties or a path to voluntary disclosure.

Individual Taxpayers: Nonresident Aliens. Nonresident aliens (NRAs) are generally taxed only on income sourced in the U.S. or effectively connected with a U.S. trade or business (ECI). NRAs are required to file Form 1040-NR to report such income. NRAs receiving U.S. wages are generally required to file by April 15, with an extension to October 15 available via Form 4868 or Form 7004. NRAs without U.S. wages, or with only ECI, have a filing deadline of June 15, with the same extension options. Certain exempt individuals, such as students or teachers, must also file Form 8843 to exclude days of physical presence for the Substantial Presence Test. NRA income is classified into two main categories. Effectively Connected Income (ECI) is income connected to a U.S. trade or business and is taxed at graduated rates, similar to U.S. citizens and residents. FDAP income (Fixed, Determinable, Annual, or Periodical) refers to passive U.S.-source income such as interest, dividends, rents, or royalties, generally subject to a flat 30% withholding tax unless a tax treaty reduces or eliminates the rate. Foreign payees certify their non-U.S. status and claim treaty benefits using the series of Forms W-8, while withholding agents report the income and taxes withheld on Forms 1042 and 1042-S.

Corporate Taxpayers: U.S. and Foreign. Corporate tax obligations vary based on incorporation status and the presence of a U.S. office. U.S. corporations (C-Corps) file Form 1120, generally due on the 15th day of the fourth month after the end of the tax year (typically April 15), with an extension to October 15 available via Form 7004. Foreign corporations with a U.S. office file Form 1120-F by the same deadlines. Foreign corporations without a U.S. office file Form 1120-F with an initial due date of June 15, and an extension to December 15 is available.

A U.S. corporation that is at least 25% owned by a foreign person must also file Form 5472 to report reportable transactions with foreign related parties. This filing follows the due date of the corporate tax return and is subject to penalties starting at $25,000 for failure to file. U.S. shareholders of Controlled Foreign Corporations (CFCs) are further required to report Subpart F income, Global Intangible Low-Taxed Income (GILTI), and Foreign-Derived Intangible Income (FDII). Form 5471 is used for disclosure, including details of Subpart F income, ownership percentages, and financial information.

Foreign Asset and Entity Disclosures. U.S. Persons with foreign accounts or interests in foreign entities face extensive disclosure obligations. FinCEN Form 114 (FBAR) must be filed electronically if the aggregate value of foreign financial accounts exceeds $10,000 at any time during the year. The FBAR has an automatic extension to October 15, and penalties for non-filing can exceed $12,921 per violation.

The FATCA Form 8938 must be filed with Form 1040 by specified U.S. persons holding certain foreign financial assets above defined thresholds. Failure to comply may result in penalties of $10,000, with incremental penalties for continued non-filing. Foreign trusts require reporting on Forms 3520 and 3520-A. Form 3520-A serves as the annual return for foreign trusts owned by U.S. persons, while Form 3520 reports transactions with foreign trusts and the receipt of large gifts or bequests from foreign persons. Penalties for failure to file these forms can be substantial, sometimes reaching 35% of the value of the gift or distribution.

Reporting Foreign Business Entities and Investments. U.S. persons with ownership or control over foreign business entities must comply with complex reporting rules. Form 5471 is used to report ownership and activities in foreign corporations, including CFCs. Form 8865 applies to U.S. partners in foreign partnerships, particularly when control is significant or property is transferred. Form 8621 reports interests in Passive Foreign Investment Companies (PFICs), including the application of Qualified Electing Fund (QEF) elections or mark-to-market elections. Penalties for non-filing are severe and often start at $10,000 per form per year. Maintaining meticulous records and timely filing is critical to avoid enforcement actions.

Other Specialized Disclosures. U.S. persons receiving foreign gifts or inheritances exceeding $100,000 from nonresident aliens must file Form 3520. Ownership of foreign real estate, whether generating income or not, may trigger additional reporting obligations, particularly under FBAR or FATCA. The rise of digital assets such as cryptocurrency has added new layers of reporting requirements; foreign wallets or exchange accounts may also be subject to FBAR or FATCA disclosures. For prior non-compliance, taxpayers can take advantage of the IRS Streamlined Filing Compliance Procedures or the Offshore Voluntary Disclosure Program to reduce penalties and regularize their filings.

Filing Deadlines, Extensions, and Penalties. Filing deadlines vary depending on taxpayer type, source of income, and whether an extension is requested. Individuals can file for an extension using Form 4868, while corporations generally use Form 7004. Penalties for failure to file, late filing, or inaccurate reporting are substantial. For individuals, the failure-to-file penalty is generally 5% per month, up to 25% of unpaid tax. FBAR non-compliance can result in civil penalties exceeding $12,921 per violation or criminal penalties. Non-filing of Forms 5471, 8865, or 8621 carries penalties starting at $10,000 per form per year, while failure to file Form 3520 can result in penalties up to 35% of the value of gifts or distributions.

Best Practices and Compliance Tips. To maintain compliance, taxpayers should maintain comprehensive records of foreign accounts, assets, and entity ownership. Reviewing filing requirements annually is essential, as thresholds and rules may change. Consultation with tax professionals is strongly recommended for complex situations involving foreign corporations, partnerships, PFICs, or trusts. Filing all required disclosure forms timely helps avoid compounded penalties and ensures transparency with the IRS.

U.S. tax reporting requires meticulous attention to detail, particularly for taxpayers with foreign income, assets, or entity interests. Compliance involves not only filing annual tax returns but also submitting multiple mandatory disclosure forms, each with its own filing rules and deadlines. Early planning, thorough documentation, and professional guidance are essential for reducing tax liability, avoiding severe penalties, and maintaining full compliance with U.S. tax law.

The requirement for U.S. persons – whether citizens, resident aliens, or certain corporations – to report worldwide income and disclose foreign assets means that meticulous record-keeping and timely filing are paramount. Given the severe, often multi-year penalties (up to $10,000 per violation, or $25,000 for some corporate forms, with much higher potential penalties for willful non-compliance), professional guidance is a necessity, not a luxury.

My practice is dedicated to transforming the burden of U.S. international tax compliance into a clear, defensible, and optimized process. I assist individuals and entities in meeting their comprehensive filing obligations and proactively resolving past non-compliance issues.:

1. Individual Income Tax Filing & Expatriate Planning. I ensure accurate reporting of worldwide income and maximum utilization of available tax relief for U.S. citizens and resident aliens (Form 1040) and proper handling of U.S.-sourced income for nonresident aliens (Form 1040-NR).

Foreign Income Relief: Structuring the optimal use of the Foreign Earned Income Exclusion (FEIE) via Form 2555 and claiming the Foreign Tax Credit (FTC) via Form 1116 to legally mitigate double taxation.
Alien Tax Status: Determining residency status, managing dual-status years, and filing Form 8843 to exclude days of presence for the Substantial Presence Test.
Treaty Positions: Preparation of Form 8833 when a tax treaty is relied upon to modify or override U.S. tax law, ensuring mandatory disclosure requirements are met to avoid penalties.

2. Corporate & Entity Tax Reporting. I manage the complexities of corporate tax obligations based on incorporation and business activity, ensuring compliance with the rules governing Controlled Foreign Corporations (CFCs) and foreign-owned U.S. entities.

Corporate Returns: Preparation and filing of domestic (Form 1120) and foreign (Form 1120-F) corporate income tax returns, including the calculation of Effectively Connected Income (ECI).
Foreign-Owned Entities: Filing Form 5472 for U.S. corporations that are 25% or more foreign-owned to report transactions with foreign related parties, avoiding the $25,000 minimum penalty for non-filing.
Complex Foreign Entities: Preparing Form 5471 (Controlled Foreign Corporations/CFCs), Form 8865 (Foreign Partnerships), and Form 8621 (Passive Foreign Investment Companies/PFICs), including electing favorable treatments like the Qualified Electing Fund (QEF).

3. Mandatory Asset & Entity Disclosure. The IRS maintains aggressive enforcement of foreign asset reporting. I ensure compliance with all mandatory disclosure forms to prevent severe, non-tax-based penalties:

FBAR (FinCEN Form 114): Timely electronic filing for any U.S. person with an aggregate balance exceeding $10,000 in foreign financial accounts.
FATCA (Form 8938): Filing the Statement of Specified Foreign Financial Assets, which reports specific assets held above defined thresholds and is filed directly with the income tax return.
Foreign Trusts & Gifts: Reporting foreign trusts (Forms 3520 and 3520-A) and reporting the receipt of large gifts or bequests from foreign persons (Form 3520), where penalties can reach 35% of the reported value.

4. Delinquency and Voluntary Disclosure. For taxpayers with prior non-compliance, I offer strategic guidance on the available IRS amnesty and penalty mitigation programs:

Streamlined Filing Compliance Procedures: Assisting eligible non-willful taxpayers to come into compliance with reduced or eliminated penalties.
Offshore Voluntary Disclosure Program (OVDP) Alternatives: Advising on the proper mechanisms to resolve delinquent filings and reduce the risk of criminal investigation or excessive civil penalties.

U.S. tax reporting requires meticulous attention to detail. Early planning, thorough documentation, and professional guidance are essential for reducing tax liability, avoiding severe penalties, and maintaining full compliance with U.S. law. Contact me to develop your personalized compliance strategy.

U.S. Tax Returns & Mandatory Disclosure Services

Foreign Tax Credit & Foreign Expenses

The Foreign Tax Credit (FTC) and the rules governing the treatment of foreign-related expenses constitute the primary mechanisms through which the United States tax system mitigates the risk of international double taxation. These provisions are codified in the Internal Revenue Code (IRC) and the corresponding Treasury Regulations, forming a complex legal framework that intersects U.S. domestic tax principles with international tax law. The principal statutory authority is found in Subchapter N of the IRC, specifically IRC §§901 through 909 for the credit itself, while the allocation and sourcing of foreign income and related expenses are governed by IRC §§861 through 865. This guide provides a comprehensive analysis of the statutory framework, regulatory guidance, and practical considerations for taxpayers navigating these rules.

Part I: The Foreign Tax Credit (FTC). The Foreign Tax Credit is a nonrefundable credit that directly reduces a U.S. taxpayer's federal income tax liability, dollar-for-dollar, by the amount of qualifying foreign income taxes paid or accrued. The foundational authority for the FTC is IRC §901, supported by detailed guidance in Treasury Regulations, particularly Treas. Reg. §§1.901–1 through 1.901–2 and §§1.903–1 for taxes paid "in lieu of" income taxes.

A. Election to Credit or Deduct (IRC §275(a)(4)). Under U.S. tax law, a taxpayer must make an annual, irrevocable election to either claim a credit or take a deduction for foreign taxes paid or accrued. The election is made in the context of filing Form 1116 for individuals or Form 1118 for corporations. A taxpayer who elects the credit reduces their U.S. tax liability directly. This approach generally provides greater economic benefit than claiming a deduction, which merely reduces taxable income and indirectly reduces tax. If a taxpayer elects the deduction, it is taken under IRC §164(a)(3), but no portion of the same foreign tax may subsequently be claimed as a credit under IRC §275(a)(4).

The election must be applied consistently across all foreign taxes in the relevant tax year. The taxpayer may not elect to claim a credit for some foreign taxes and a deduction for others. This consistency requirement is reinforced by the IRS through audit practice and administrative guidance, ensuring that taxpayers do not selectively apply the credit to maximize benefit in a manner inconsistent with the statutory election framework.

B. Qualifying Tax Requirements (IRC §901; Treas. Reg. §1.901–2). For a foreign levy to constitute a qualifying tax eligible for the FTC, it must satisfy multiple criteria, derived from IRC §901 and elaborated in Treas. Reg. §1.901–2. These include:

Imposed on the Taxpayer: The tax must be legally and actually the taxpayer’s liability. Third-party or pass-through obligations do not satisfy this criterion.
Paid or Accrued: Depending on the taxpayer's accounting method, the tax must be either paid or accrued. Cash-method taxpayers may elect to claim the credit in the year the tax is accrued, under IRC §905(a), rather than when the payment is made, permitting synchronization with income recognition.
Legal and Actual Liability: Only the portion of the foreign tax that constitutes the taxpayer's actual legal liability qualifies. Amounts that may be refunded, or taxes reduced pursuant to an applicable tax treaty, must be adjusted downward to reflect the net liability.
Income Tax or In-Lieu-of Tax: The levy must be an income tax or a tax paid in lieu of an income tax, pursuant to IRC §903. To satisfy the income tax requirement, the tax generally must be imposed on net gain (as opposed to gross receipts or turnover), a principle known as the Net Gain Requirement, detailed in Treas. Reg. §1.901–2.

Taxes that do not meet these requirements, such as value-added taxes, sales taxes, property taxes, or taxes associated with income that has been excluded under the Foreign Earned Income Exclusion (FEIE) in IRC §911, are generally disqualified from the FTC. This distinction prevents taxpayers from claiming credit for taxes that do not constitute true foreign income taxation.

Part II: The Foreign Tax Credit Limitation (IRC §904). The most intricate element of the FTC regime is the statutory limitation on the credit, codified in IRC §904. The purpose of this limitation is to prevent a taxpayer from using foreign taxes paid on foreign-source income to offset U.S. tax on domestic-source income – a practice commonly referred to as “cross-crediting.”

A. The Limitation Formula (IRC §904(a)). The statutory formula for the FTC limitation ensures that the credit only offsets U.S. tax attributable to foreign-source income. The limitation is calculated as the lesser of the actual foreign taxes paid or accrued, or the hypothetical U.S. tax on foreign-source taxable income. Specifically, the calculation is expressed as:

FTC Limitation=U.S. Tax Liability (Pre-Credit)×Taxable Income from Foreign SourcesTotal Taxable Income from All SourcesFTC Limitation=U.S. Tax Liability (Pre-Credit)×Total Taxable Income from All SourcesTaxable Income from Foreign Sources

This formula requires accurate determination of both foreign-source income and total taxable income. Failure to correctly compute these figures can result in under- or over-claimed credits, leading to potential IRS adjustments and penalties.

B. Separate Limitation Categories (“Baskets”) (IRC §904(d)). To further constrain cross-crediting, IRC §904(d) mandates that foreign income be grouped into separate limitation categories, commonly referred to as “baskets.” Each basket is subject to its own FTC limitation calculation. The principal categories are:

Foreign Branch Category: Income attributable to a qualified foreign branch.
Passive Category: Income generally considered passive, including dividends, interest, rents, and royalties.
General Category: Active business income not otherwise allocated to a separate basket.
Section 951A Category (GILTI): Income inclusions under the Global Intangible Low-Taxed Income regime.

Each basket is treated independently for purposes of applying the FTC limitation, and foreign taxes are allocated to the basket corresponding to the underlying income source.

C. Carryback and Carryforward of Unused Taxes (IRC §904(c)). When foreign taxes exceed the statutory limitation for a given year, IRC §904(c) permits taxpayers to preserve value by carrying the excess backward one year or forward for ten subsequent years. This carryover mechanism ensures that taxpayers are not permanently deprived of credit for high foreign tax rates. However, Section 951A/GILTI-related taxes are exempt from carryback or carryforward, reflecting the special treatment accorded to these income inclusions under IRC §951A and related regulations.

Part III: Allocation and Apportionment of Foreign Expenses. The FTC limitation formula requires a numerator representing taxable foreign-source income. To determine this amount accurately, taxpayers must subtract properly allocated and apportioned deductions from gross foreign-source income. IRC §861 and its associated regulations govern this complex process.

A. Statutory Authority and Rationale (IRC §861). IRC §861 provides the overarching rules for distinguishing U.S.-source and foreign-source income. The allocation and apportionment principles embedded in Treas. Reg. §§1.861–8 through 1.861–17 require that deductions be allocated to a specific class of gross income to which they are “definitely related,” and then apportioned between domestic and foreign sources.

This process ensures that deductions do not inadvertently reduce U.S. tax on domestic-source income while also preserving the integrity of the FTC limitation.

B. The Three-Step Process for Deductions (Treas. Reg. §§1.861–8 through 1.861–17). The deduction process consists of:

Direct Allocation: Expenses that can be directly traced to a class of income (e.g., cost of goods sold allocated to sales revenue) are allocated to that class.
Apportionment Between U.S. and Foreign Source: When allocated expenses are associated with both U.S. and foreign-source income, they are apportioned using prescribed methodologies. For example:
- Interest Expense: Apportioned according to the tax basis or fair market value of assets producing the income, as detailed in Treas. Reg. §§1.861–9 and 1.861–11.
- Stewardship Expenses: Allocated to dividend income or income from controlled entities to reflect the indirect costs of managing investments.
Foreign Tax Apportionment: Foreign taxes themselves are allocated and apportioned under Treas. Reg. §1.861–20 to determine the appropriate FTC basket for purposes of the §904 limitation.

Through this framework, U.S. taxpayers ensure that expenses and taxes are accurately matched to income categories, maintaining compliance with statutory and regulatory requirements.

Part IV: Deduction of Foreign Expenses and the Disallowance Rule.

A. Ordinary and Necessary Business Expenses. Foreign business expenses incurred in the conduct of a trade or business are deductible under IRC §162 (trade or business expenses) or IRC §212 (expenses for the production of income), provided they are ordinary and necessary. These expenses may include, for example, local payroll costs, office rent, travel, and utilities. The geographic location of the expense does not inherently affect deductibility; what matters is the relationship of the expense to the income-producing activity.

B. The Disallowance Rule for Excluded Income (IRC §911(d)(6)). The Foreign Earned Income Exclusion (FEIE) under IRC §911 provides for the exclusion of certain foreign income. However, expenses and foreign taxes related to excluded income cannot be claimed as deductions or credits, to prevent duplicative tax benefits.

Deduction Disallowance: IRC §911(d)(6) bars deductions allocated and apportioned to excluded foreign income. Treasury Regulation §1.911–6 provides detailed rules for allocation, ensuring that deductions are proportionately reduced by the excluded income amount.
FTC Disallowance: Similarly, any foreign taxes paid on excluded income cannot generate an FTC under Treas. Reg. §1.911–6(c). This principle prevents taxpayers from receiving both an income exclusion and a credit for taxes paid on the same income, preserving the integrity of the U.S. tax system.

The disallowance rules require meticulous recordkeeping and careful allocation, as taxpayers claiming the FEIE must adjust both their income and deduction calculations, including foreign taxes, to comply with these provisions.

The Foreign Tax Credit and the associated rules for foreign expense allocation and apportionment are fundamental to ensuring that U.S. taxpayers are not subject to double taxation on income earned abroad. IRC §§901–909 provide the legal basis for claiming the credit, while IRC §§861–865 establish the framework for sourcing and allocating income and deductions. The FTC limitation under IRC §904, the separate limitation baskets, and the carryback/carryforward provisions together form a highly structured system designed to prevent abuse, ensure proper matching of expenses to income, and harmonize U.S. domestic taxation with international tax obligations. Navigating this regime requires a careful synthesis of statutory authority, Treasury Regulations, and practical tax compliance, particularly for taxpayers engaged in international business operations or receiving foreign-source passive income.

The Foreign Tax Credit (FTC) is the most powerful tool for eliminating international double taxation for U.S. taxpayers. However, the associated rules in IRC §§ 901–909 (for the credit) and §§ 861–865 (for expense allocation) are among the most intricate in the U.S. tax code. Incorrect application of the limitation formula or misallocation of expenses can drastically reduce the credit's value or lead to IRS penalties.

My practice specializes in navigating this technical regime to maximize your FTC benefits while ensuring rigorous compliance with U.S. expense allocation rules. I provide strategic planning, precise calculations, and meticulous compliance services for all aspects of the Foreign Tax Credit and foreign expense treatment for individuals and corporations.

1. Maximizing the Foreign Tax Credit (IRC §901). I advise on the fundamental requirements to ensure maximum credit eligibility:

Credit vs. Deduction Election: Advising on the critical annual, irrevocable election to either credit (dollar-for-dollar offset) or deduct foreign taxes paid under IRC §275(a)(4), which often results in superior tax savings.
Qualifying Tax Analysis: Reviewing foreign levies (income, withholding, "in lieu of" taxes) against the regulatory criteria, particularly the Net Gain Requirement (Treas. Reg. §1.901−2), to confirm the tax is a creditable income tax.
Accrual Election: Strategically applying the IRC §905(a) election for cash-method taxpayers to claim the credit in the year the tax is accrued, aligning with income recognition.

2. Managing the FTC Limitation & Baskets (IRC §904). The FTC Limitation is the most complex constraint. I focus on optimizing the three components of the limitation formula:

Limitation Formula Calculation: Precisely calculating the maximum allowable credit to prevent cross-creditingagainst U.S.-source income.
Separate Limitation Categories (Baskets): Correctly classifying income and taxes into the required separate baskets (e.g., General, Passive, Foreign Branch, GILTI) to ensure each category’s limitation is calculated independently.
Carryover Management: Calculating and tracking carryback (one year) and carryforward (ten years) of unused foreign taxes under IRC §904(c) to preserve the value of high foreign tax payments.

3. Strategic Allocation of Expenses (IRC §§861–865). The accurate determination of your taxable foreign-source income is dependent on proper expense allocation. My services include:

Deduction Allocation & Apportionment: Applying the complex rules of Treas. Reg. §1.861−8 to correctly allocate and apportion common deductions—especially interest expense (based on asset value) and stewardship expenses—between U.S. and foreign sources.
Foreign Tax Apportionment: Ensuring foreign taxes are correctly allocated to the appropriate FTC baskets under Treas. Reg. §1.861−20.
Maximizing the Numerator: Strategic allocation that maximizes the foreign-source taxable income (the numerator in the §904 limitation formula) to increase the maximum allowable credit.

4. Compliance and Planning

Return Preparation: Preparation of the required Forms 1116 (Individuals) or 1118 (Corporations) to report the foreign tax credit.
FEIE Disallowance: Ensuring strict adherence to the disallowance rule under IRC §911(d)(6) and Treas. Reg. §1.911−6, which prevents the double benefit of claiming both the Foreign Earned Income Exclusion (FEIE) and the FTC on the same income.

Navigating the FTC rules is essential to avoiding double taxation. Contact me to develop a robust, compliant, and tax-efficient strategy for your foreign taxes and expenses.

Foreign Tax Credit (FTC) & Expense Allocation Services

Tax Arbitrage and Tax Treaties

In an increasingly globalized economy, high-net-worth individuals, multinational corporations, and investors routinely operate across multiple tax jurisdictions. Each jurisdiction applies its own set of tax laws, rates, and classification rules, creating opportunities – and risks – for taxpayers engaged in cross-border transactions. Two critical mechanisms in this landscape are tax arbitrage and tax treaties. Understanding how they work, as well as their limitations under U.S. law, is essential for structuring international investments efficiently and lawfully.

This article provides an in-depth exploration of tax arbitrage and treaty planning, and illustrates how I leverage these tools to help clients minimize their overall tax burden while remaining fully compliant with U.S. tax law.

I. Tax Arbitrage: Concept and Mechanisms. Tax arbitrage refers to the practice of exploiting differences in the tax rules or rates of two or more countries (or jurisdictions) to reduce overall tax liability. At its core, tax arbitrage involves identifying mismatches in tax treatment and strategically structuring transactions, entities, or investments to benefit from those differences.

In international taxation, tax arbitrage commonly manifests in several ways:

Deduction/No-Inclusion Arbitrage: A taxpayer may generate a deductible expense in a high-tax jurisdiction while simultaneously having the related income taxed at a lower rate – or not taxed at all – in another jurisdiction. This can arise, for example, when interest payments, royalties, or service fees cross borders under carefully structured agreements.
Entity and Instrument Classification Arbitrage: Differences in how countries classify entities or financial instruments can produce favorable outcomes. For instance, a hybrid entity may be treated as a partnership in the U.S., allowing for pass-through treatment of income, while the foreign jurisdiction treats it as a corporation, resulting in deferral or exemption of taxation. Similarly, hybrid financial instruments can be structured to produce interest deductions in one country and exempt income in another.

These arbitrage opportunities must be pursued with caution, as they often fall under anti-abuse scrutiny, both in the U.S. and abroad.

II. Tax Treaties: Purpose and Practical Effects. Income Tax Treaties, also referred to as Double Taxation Agreements (DTAs), are bilateral treaties designed to prevent double taxation, reduce tax evasion, and facilitate cross-border investment. These treaties allocate taxing rights between the source country (where income originates) and the residence country (where the taxpayer is domiciled) for various categories of income, such as dividends, interest, royalties, and business profits.

Key objectives of tax treaties include:

Eliminating Double Taxation: By determining which jurisdiction has the primary right to tax specific income streams, treaties reduce or eliminate scenarios where the same income is taxed by both countries.
Providing Certainty for Cross-Border Transactions: Reduced withholding rates and clear definitions of income and residency foster predictable tax outcomes, encouraging international trade and investment.
Promoting Information Exchange and Compliance: Modern treaties establish mechanisms for sharing information between tax authorities, discouraging evasion and promoting transparency.

In the U.S., treaties generally take precedence over domestic law under the Supremacy Clause. However, under the "last-in-time" principle, Congress may enact a statute that overrides an existing treaty – or ratify a new treaty that supersedes prior law – provided the legislative intent is explicit.

III. Anti-Abuse Measures: Preventing Treaty Arbitrage. While tax arbitrage can reduce tax liability, it can also cross into treaty abuse, which is closely monitored by the IRS and U.S. Treasury. A primary example of treaty-related arbitrage is treaty shopping.

Treaty shopping occurs when a taxpayer resident in a third country – often one without a favorable treaty with the U.S. – attempts to benefit indirectly from a treaty between the U.S. and another country by interposing a conduit entity.

Example: Investor A resides in Country X, which has no treaty with the U.S. Country C, however, has a highly favorable treaty. Investor A establishes Conduit Co. in Country C to receive U.S.-source dividends. The goal is to invoke the lower U.S. withholding tax rate available under the U.S.–Country C treaty, thereby avoiding the higher tax that would apply if the dividend were received directly.

To combat such arrangements, U.S. treaties include Limitation on Benefits (LOB) provisions, often found in Article 22 of U.S. Model Treaties. These provisions deny treaty benefits to entities that fail objective tests demonstrating a substantive connection to the treaty country. Common tests include:

Publicly Traded Test: The entity's shares are widely traded on a recognized stock exchange.
Ownership and Base Erosion Test: The entity is primarily owned by qualified residents and does not excessively divert income to unrelated non-residents.
Active Trade or Business Test: The entity conducts genuine business operations in its country of residence, and income is earned in connection with these operations.
Governmental or Tax-Exempt Test: Applies to entities that are governmental or tax-exempt organizations.

Hybrid Entities and IRC § 894. A related anti-abuse mechanism is Internal Revenue Code § 894. This provision targets hybrid entities and instruments that produce double non-taxation by being treated differently in the U.S. and the treaty partner's jurisdiction.

Under IRC § 894(c), a foreign person cannot claim treaty benefits for U.S.-source income received through an entity if:

The income is not recognized as income by the foreign jurisdiction, and
The foreign jurisdiction does not impose tax when the income is distributed to the foreign recipient.

This rule prevents strategies in which a single item of income escapes taxation in both countries – a practice sometimes called deduction/double exemption arbitrage.

Tie-Breaker Rules for Individuals. For individual taxpayers with potential dual residency under domestic laws, treaties include tie-breaker rules to determine the country of residence for treaty purposes. The rules generally follow a hierarchy:

Permanent Home: The country where the taxpayer maintains a permanent home.
Center of Vital Interests: Where personal and economic relations are closer.
Habitual Abode: Where the individual ordinarily resides.
Nationality: The taxpayer’s country of citizenship.

If these tests do not resolve the issue, the Mutual Agreement Procedure (MAP) allows competent authorities of the treaty countries to determine residency.

IV. Practical Applications: How I Help Clients. As a tax attorney, I guide clients in structuring cross-border transactions and investments in ways that are fully compliant with the Internal Revenue Code, Treasury Regulations, and relevant tax treaties, while optimizing their global tax position. My services include:

Tax Treaty Planning: Evaluating applicable treaties to maximize benefits, including reduced withholding rates on dividends, interest, and royalties, and ensuring eligibility under LOB provisions.
Entity Structuring: Advising on the use of hybrid entities or partnerships in cross-border arrangements to achieve favorable tax treatment without violating anti-abuse rules.
Arbitrage Analysis: Identifying legitimate tax arbitrage opportunities, such as deduction/no-inclusion outcomes or favorable classification of instruments.
Compliance and Documentation: Preparing filings, disclosures, and substantiation to defend treaty benefits and ensure transparency with the IRS.
Dual Residency Management: Navigating tie-breaker rules for individuals with potential dual residency and resolving conflicts through the Mutual Agreement Procedure when necessary.
IRS Audit Support: Representing clients during IRS or foreign tax authority inquiries related to treaty claims, hybrid entities, or arbitrage structures.

Through careful planning, I help clients lawfully minimize their global tax liability, mitigate audit risk, and create clarity and certainty in complex international tax environments.

Tax arbitrage and treaties are powerful tools in international tax planning, but they require nuanced understanding and meticulous implementation to avoid pitfalls. By combining knowledge of U.S. tax law, treaty provisions, anti-abuse rules, and practical structuring techniques, taxpayers can achieve significant tax efficiency while remaining fully compliant. As an experienced practitioner, I assist clients in navigating this complex landscape, translating sophisticated tax rules into actionable strategies that deliver measurable benefits.

In the global economy, Tax Arbitrage and Income Tax Treaties are essential tools for managing and reducing cross-border tax liabilities. However, deploying these mechanisms requires a deep understanding of anti-abuse provisions like Limitation on Benefits (LOB) and IRC §894. Missteps can lead to the denial of treaty benefits, imposition of domestic withholding, and severe penalties.

My practice offers sophisticated advisory services to help high-net-worth individuals, multinational corporations, and investors lawfully optimize their global tax position while fully complying with U.S. and international anti-abuse measures. I provide counsel on structuring transactions to benefit from jurisdictional differences and bilateral agreements while ensuring your planning is robust, defensible, and fully transparent to tax authorities.

1. Tax Treaty Planning and Defense. I leverage the full scope of U.S. Income Tax Treaties to achieve optimal tax outcomes and compliance certainty.

Treaty Benefit Maximization: Evaluating treaties to secure reduced U.S. withholding tax rates on passive income (dividends, interest, royalties) at the source, and advising on appropriate Forms W-8 compliance.
Limitation on Benefits (LOB) Analysis: Structuring entities and investments to meet the objective LOB requirements—such as the Active Trade or Business Test, Publicly Traded Test, or Ownership and Base Erosion Test—to ensure treaty benefits are not denied due to suspected treaty shopping.
Dual Residency Resolution: Navigating treaty-specific tie-breaker rules to conclusively determine an individual's country of residence for tax purposes, often involving close analysis of permanent home and center of vital interests.

2. Hybrid Entity & Arbitrage Structuring. I analyze entity and instrument classifications across jurisdictions to identify compliant arbitrage opportunities without triggering anti-abuse rules.

Hybrid Entity Planning: Advising on the strategic use of entities that are classified differently by the U.S. and foreign country (e.g., as a corporation in one and a partnership in the other) to achieve tax efficiencies like income deferral or reduced tax drag.
Deduction/No-Inclusion Compliance: Analyzing cross-border payments (interest, royalties, services) to achieve a deduction in a high-tax jurisdiction and non-inclusion or reduced tax in the recipient jurisdiction, while ensuring compliance with foreign anti-hybrid rules.
IRC § 894 Analysis: Ensuring that income received through hybrid entities or arrangements is recognized as "income" by the foreign jurisdiction, thereby avoiding the rule under IRC §894(c) that denies treaty benefits for arrangements resulting in double non-taxation.

3. Audit Defense and Dispute Resolution. I provide robust defense and resolution services for treaty-related disputes.

Treaty-Based Position Disclosure: Preparing the necessary Form 8833, Treaty-Based Return Position Disclosure, to legally protect treaty positions and avoid potential failure-to-file penalties.
IRS Audit Representation: Defending treaty claims, entity classifications, and arbitrage structures during IRS examinations.
Competent Authority Assistance: Initiating and managing cases under the Mutual Agreement Procedure (MAP) of a tax treaty to resolve instances of actual or potential double taxation, particularly those arising from transfer pricing adjustments or dual residency conflicts.

Through careful planning, I help clients lawfully minimize their global tax liability, mitigate audit risk, and create clarity and certainty in complex international tax environments. Contact me to translate complex treaty and arbitrage rules into actionable tax-efficient strategies.

Tax Arbitrage and Tax Treaties: Strategic Planning & Compliance

Viacheslav Kutuzov | International & U.S. Taxation Expert

Viacheslav Kutuzov | International & U.S. Taxation Expert

We minimize your taxes domestically and internationally...

Viacheslav Kutuzov

VIACHESLAV KUTUZOV, Esq.

International and U.S. Taxation Expert

New York Tax Attorney & Counselor-at-Law (6192033)

admitted to practice before the IRS (No.00144810-EA)

55 Broadway, Floor 3, New York, New York 10006

Email to Viacheslav Kutuzov

Telegram of Viacheslav Kutuzov

WhatsApp of Viacheslav Kutuzov

Viber of Viacheslav Kutuzov

Instagram of Viacheslav Kutuzov

YouTube Channel of Viacheslav Kutuzov

Google Maps Address of Viacheslav Kutuzov

We apply international standards of confidentiality

ISO / IEC 27001 Information security management

U.S. Taxation.pdf

bottom of page