Withholding is generally required on any item of U.S. Source FDAP income.
In general, foreign persons (individuals and entities) are subject to U.S. income tax at a 30% rate on FDAP income they receive from U.S. sources. Taxation is achieved by means of the withholding required to be made by the payor of the U.S. source FDAP income to foreign beneficial owners. This video provides an overview of FDAP income sources and the relevant withholding forms for Section 1441/1442 withholding.
Mike Burgess, J.D.
- Serves as a senior manager with Crowe LLP’s international tax group
- Has more than 20 years of experience in international tax including both compliance and planning for public and private companies
- Has a broad range of industry experience, including manufacturing and distribution, retail and technology, among others
- Throughout his career he has acquired extensive experience in international compliance issues including completion and review of all U.S. international tax forms
- Since 2010 he has focused on providing international tax services to publicly and privately held multinational companies in the middle market on a wide range of international tax issues, including, in addition to the above, structure planning, mergers and acquisition, cross-border transactions and Subpart F analysis, GILTI, FDII, BEAT, and foreign tax credits
- Prior to joining Crowe, he spent more than 10 years in Big 4 public accounting firms where he gained an extensive background in implementing global holding company structures designed to improve a company’s tax positions and efficiently manage cash through intercompany financing and cash planning
- Has specific experience in development and implementation of international structuring and restructuring projects
- J.D. degree, Lewis & Clark College
Danish N. Meherally, J.D., LL.M.
- Manager in the Atlanta office of Crowe LLP
- Practice emphasizes all aspects of international tax
- LL.M. degree in tax , University of Florida School of Law; J.D. degree, Ave Maria School of Law
- Can be contacted at [email protected]
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