A Greenstein, Rogoff, Olsen & Co. Analytical Report

This document has been prepared for the assistance of those interested in residing, investing and/or doing business in the United States. The United States tax laws are very complex and often change and the U.S. government acts strongly against violation of tax rules. The material covers areas of the U.S. tax law that many Foreign companies and individuals coming to the United States may encounter.

Outline

Foreword

Part 1: U.S. Income Tax Issues for Foreign Owned Corporations

part 2: U.S. Income Tax Issues for Resident & Nonresident Aliens

Exhibits

Exhibit 1 — Deferal of deduction on payments to related foreign persons

Exhibit 2 — Withholding tax on amounts paid to foreign persons

Exhibit 3 — Thin capitalization

Exhibit 4 — Low or no interest rate loans

Exhibit 5 — Selected tax accounting elections and disclosure

Exhibit 6 — Tax return filing requirements

Exhibit 7 — Survey of foreign direct investment in the U.S.

Exhibit 8 — Organisations and start-up expenditures

Exhibit 9 — Taxation of foreign employees

Appendices

Copies of forms 1001, 1040, 1040NR, 1042, 1042S, 5471, 5472, 8300 AND TD F 90-22.1