International Tax & Cross-Border Payments
Treaties, PE/ECI, branch profits tax, the W-8 series, 1042/1042-S, transfer pricing, customs valuation, related-party payments, Section 1446, 5471/8865/8858 and FBAR.
10 articles · last reviewed 2026-07-18
The U.S.-China treaty is not an automatic exemption: PE, ECI and Form 8833
A treaty may limit federal income tax only when the taxpayer, business facts, income category, and procedural requirements support the position.
Read article → International Tax & Cross-Border PaymentsHow branch profits tax changes the branch-vs.-subsidiary decision
Comparing corporate income-tax rates misses branch profits tax—the second layer designed to approximate a dividend—and the effects of branch interest and c
Read article → International Tax & Cross-Border PaymentsWhich form: W-8BEN-E, W-8ECI, W-8IMY, or W-9?
The form is not selected by the vendor’s country alone.
Read article → International Tax & Cross-Border PaymentsPayments to a Chinese parent: Form 1042/1042-S and withholding workflow
Deductibility, withholding, deposit timing, and information reporting are connected but distinct questions.
Read article → International Tax & Cross-Border PaymentsDefensible transfer pricing for intercompany service fees
A contract and year-end invoice show how much was charged.
Read article → International Tax & Cross-Border PaymentsOne shipment, two rulebooks: reconciling IRS transfer pricing and CBP customs value
The IRS asks whether U.S.
Read article → International Tax & Cross-Border PaymentsManagement fee, interest, royalty, or dividend? A cross-border payment matrix
The same cash flow can follow entirely different sourcing, withholding, deduction, treaty, and reporting rules depending on the legal rights and commercial
Read article → International Tax & Cross-Border PaymentsU.S. partnerships with Chinese partners: Section 1446 withholding
Section 1446(a) generally withholds on effectively connected taxable income allocable to a foreign partner, not only when the partnership distributes cash.
Read article → International Tax & Cross-Border PaymentsWhen a U.S. company owns a China or Hong Kong entity: Forms 5471, 8865 and 8858
The foreign registration name does not choose the form.
Read article → International Tax & Cross-Border PaymentsDoes a U.S. company need an FBAR for China or Hong Kong accounts?
FBAR is a Bank Secrecy Act report filed electronically and separately with FinCEN, not an attachment to the business income-tax return.
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