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US Inbound Tax · Insights

US Inbound Tax insights

Plain-English guidance on US tax rules for foreign businesses and investors operating in the US.

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Individual Tax PreparationBusiness & Corporate TaxTax Planning & StrategyBusiness Tax CreditsIRS Audit DefenseTax Debt ResolutionInternational TaxState & Local Tax (SALT)Estate Income TaxFlorida 1031 ExchangeNonprofit Tax ServicesExpats / Expatriate TaxTax Court RepresentationFederal TaxTax Risk ServicesTransfer PricingTax ComplianceUS Inbound TaxM&A TaxIRS Tax AdvocateOutbound TaxTax Treaty PlanningFIRPTA & Foreign Real EstateForeign Business Expansion
The Branch Profits Tax: The Second Layer on a Foreign Corporation's US Branch
US Inbound Tax
Mar 9, 2026·7 min read

The Branch Profits Tax: The Second Layer on a Foreign Corporation's US Branch

A foreign corporation running a US branch faces two layers of tax: 21% on the branch's profits, then a 30% branch profits tax on what's repatriated. Understanding IRC §884 — and the treaty that cuts it — is the difference between a 44% and a sub-25% effective rate.

MK Tax & Accounting Team
ECI vs. FDAP: Net Taxation, 30% Gross Withholding, and the W-8 Forms That Decide
US Inbound Tax
Feb 24, 2026·7 min read

ECI vs. FDAP: Net Taxation, 30% Gross Withholding, and the W-8 Forms That Decide

The same dollar of US income can be taxed at 21% net or 30% gross depending on one classification: effectively connected income or FDAP. The W-8 form your payer holds is what sets the rate.

MK Tax & Accounting Team
Foreign Companies Doing Business in the US: Nexus, ECI, Form 1120-F, and Treaty Protection
US Inbound Tax
Feb 10, 2026·7 min read

Foreign Companies Doing Business in the US: Nexus, ECI, Form 1120-F, and Treaty Protection

If your foreign corporation touches the US market, the questions are: do you have a taxable presence, is your income effectively connected, and does a treaty protect you? Getting the answer wrong means back tax, penalties, and a lost treaty claim.

MK Tax & Accounting Team

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