The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify U.S. and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The U.S. currently has income tax treaties with approximately 58 countries. This article discusses the implications of the United States- France Income Tax Treaty.
There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the United States is a party. In many cases, these provisions are patterned after or similar to the United States Model Income Tax Convention, which reflects the traditional baseline negotiating position. However, each tax treaty is separately negotiated and therefore unique. As a consequence, to determine the impact of treaty provisions in any specific situation, the applicable treaty at issue must be analyzed. The United States- France Income Tax Treaty is no different. The treaty has its own unique definitions. We will now review the key provisions of the United States- France Income Tax Treaty and the implications to individuals attempting to make use of the treaty.
Definition of Resident
The tax exemptions and reductions that treaties provide are available only to a resident of one of the treaty countries. For U.S. tax purposes, the U.S. classifies the following individuals as residents:
1. All lawful permanent residents for immigration purposes (“green card” holders).
2. Those who meet a “substantial presence test.” (Present in the United States for at least 183 days in the current year or, alternatively in the United States for at least 31 days in the current year and a total of 183 equivalent days during the last three years. For the purpose of this 183-equivalent-day requirement, each day present in the United States during the current year counts as a full day, each day in the first preceding year as one-third of a day and each day in the second preceding year as one-sixth of a day).
Under the domestic law of France, an individual is considered to be a tax resident if at least one of the four criteria listed below is met.
1. The habitual abode of the person or family is in France.
2. France is the principal place of sojourn (more than 183 days in a calendar year).
3. Professional activities are carried out in France.
or
4. France is the center of economic interests.
Under the U.S.-France bilateral income tax treaty, tax residency is first determined under the law of the country that asserts the power to tax. If the individual is considered to be resident under the laws of both the United States and France, the treaty provides a “tie-breaker” provision to determine the country of residence. This tie-breaker test generally includes as criteria, in order of importance, permanent residence, center of personal and economic relations, habitual abode, and, if none of the foregoing tests is determinative, the decision of the competent authorities.
For example, an alien who qualifies as a U.S. resident under the substantial presence test pursuant to U.S. tax law may simultaneously qualify as a resident of France under its definition of resident. To resolve this issue, the United States has included tie-breaker provisions in the United States- France Income Tax Treaty. The first test is where the individual has a permanent home. If that test is inconclusive because the individual has a permanent home available to him in both States, he will be considered to be a resident of the Contracting State where his personal and economic relations are closest, i.e., the location of his “center of vital interests.” If that test is also inconclusive, or if he does not have a permanent home available to him in either State, he will be treated as a resident of the Contracting State where he maintains an habitual abode. If he has an habitual abode in other States or in neither of them, he will be treated as a resident of his Contracting State of citizenship. If he is a citizen of both States or of neither, the matter will be considered by the competent authorities, who will attempt by mutual agreement to assign a single State of residence.
Below, please see Illustration 1 which provides an example of how a treaty-tie breaker can be analyzed and resolved for an individual under the United States- France Income Tax Treaty.
Illustration 1.
Charles de Gaulle is a citizen and resident of France. Charles owns Zoomtube, a company incorporated in France that is in the process of expanding to the much more lucrative U.S. market by opening a branch office in the United States. Charles is divorced and maintains an apartment in India, where she spends every other weekend visiting her children. Charles’ first wife, who kept their house in their divorce, has never left France. Charles becomes a U.S. resident alien under the substantial presence test as he operates Zoomtube’s U.S. branch. In the United States Charles owns a luxury condominium in New York where he lives with his second wife.
Because Charles is considered a resident of both the United States and France, the treaty tie-breaker procedures must be analyzed to determine which country has primary taxing jurisdiction. With an apartment in France and a condominium in the United States, Charles has a permanent home available in both countries. With Charles’ children and his home office in France as opposed to the lucrative portion of his business and his new wife in the United States, Charles does not have a center of vital interests in either country. Furthermore, because Charles regularly spends time in both countries, he arguably has a habitual abode in both. As a result, under the treaty tie-breaker, Charles may be considered a resident of France because he is a citizen of France.
Permanent Establishment
A central issue for any company exporting its goods or services is whether it is subject to taxation by the importing country. Most countries assert jurisdiction over all the income from sources within their borders, regardless of the citizenship or residence of the person receiving that income. Under a permanent establishment provision, the business profits of a resident of one treaty country are exempt from taxation by the other treaty country unless those profits are attributable to a permanent establishment located within the host country. A permanent establishment includes a fixed place of business, such as a place of management, a branch, an office, a factory or workshop. A permanent establishment also exists if employees or other dependent agents habitually exercise in the host country an authority to conclude sales contracts in the taxpayer’s name.
The United States-France Income Tax Treaty defines a permanent establishment as a fixed place of business through which the business of an enterprise is wholly or partly carried on. This includes the following: 1) a place of management; 2) a branch; 3) an office; 4) a factory; 5) a workshop; and 6) a mine, an oil or gas well, a quarry or any other place of extraction of natural resources.
The term “permanent establishment” shall also include a building site or construction or installation project, or an installation or drilling rig or ship used for the exploration or to prepare for the extraction of natural resources, but only if such site or project lasts, or such rig or ship is used, for more than twelve months.
The treaty specifically excludes certain activities from the definition of permanent establishment. Some of these activities are: 1) the use of facilities for the purpose of storage, display, or delivery of goods or merchandise belonging to the enterprise; 2) the maintenance of a stock of goods or merchandise belonging to the resident for the purpose of storage, display, or delivery; 3) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterprise; 4) the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise, or of collecting information, for the enterprise; 5) the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character; 6) the maintenance of a fixed place of business solely for combination of the activities mentioned above.
Business Profits
Under the U.S.-France Income Tax Treaty, the business profits of a resident of one treaty country are exempt from taxation by the other treaty country unless those profits are attributable to a permanent establishment located within the host country. Consequently, under the U.S.-France Income Tax Treaty, a French corporation eligible for treaty benefits is not subject to federal income taxes on business profits unless such profits are attributable to a “permanent establishment” in the United States. Although the United States- France Income Tax Treaty firmly establishes the business profits rule for corporations. The tax consequences of operating a permanent establishment through a partnership will generally be attributable to partners according to the usual rules therefore as if each partner had the permanent establishment. However, there still remains uncertainty as to how partnerships are taxed under the treaty. Under the domestic laws of the United States and France, the source of partnership income is determined differently, and certain partnerships are taxed in a different fashion. This creates double taxation problems for all partners, but especially for French residents who are United States citizens.
For purposes of United States federal tax law, each partner is considered to have earned that proportion of partnership income and to have incurred that proportion of partnership deductions that corresponds to his proportionate interest in the partnership (unless there is a valid special allocation). See IRC Section 704. The distributive share of each partner includes a share of each type of income derived from sources within each country in which the partnership earns income. To illustrate, assume that a taxpayer is 75 percent partner in a partnership with $300,000 of income from long term capital gains to which no deductions are attributable. The other $260,000 is United States-source business income to which $200,000 of deductions are attributable. The partnership also has $400,000 gross income from sources outside the United states to which $300,000 in deductions are attributable. The taxpayer has $30,000 United States-source long term capital gain (.75 x $40,000) and $45,000 of net United States-source business income (.75 x $260,000) less (.75 X $200,000). Net business income from foreign sources (as well as net foreign-source income) is $75,000 (.75 x $400,000) less (.75 x $300,000). The taxpayer would be subject to United States tax at ordinary income rates on the business income and at the special reduced rate on the capital gains income. Within the limits of the foreign tax credit rules, a taxpayer may take a credit for 75% of the foreign income tax paid on the business income from foreign sources. See Rev. Rul. 67-158, 1967-1 C.B. 188.
This general rule is subject to two exceptions. First, when the partner only receives a share if there is income from a specific source, all of that partner’s share is income from that source. Second, when the partner receives a guaranteed payment regardless of partnership earnings, the payment is considered to be for services as though paid under an employment contract, and the payment has its source in the place where the partner’s services are rendered. The French source rule for partners who perform services outside France is the same as the general United States rule: a pro rata share of income from each partnership source. However, the rule for a partner who performs services in France is that all of his partnership income is considered to be from French sources. This means that the partners in the aggregate may have more French-source income than the partnership does where any partner performs services in France. See Business Impact of the United States France Income Tax Protocol, Herbert I. Lazerow, March 1982 Vol. 19. No. 2 San Diego Law Review.
An area of potential concern is that many American partners residing outside the United States are paid part of their partnership earnings in the form of “guaranteed payments” for services rendered overseas. Under U.S. tax law, these are considered to be foreign sources on a similar basis as salary, and in the past have enabled partners to claim both foreign earned income deductions, foreign exclusions, and foreign tax credits. The published U.S. and French interpretations on the treatment to be accorded a guaranteed payment are markedly different. The French interpretation considers these payments as salary to the partner from the partnership, taxable in France under Article of the treaty. The French do not permit exclusions on such payments. Hence, in a case where a partner received a guaranteed payment plus other partnership earnings from U.S. sources, the implication is that these earnings may be taxed in France on 100 percent of the guaranteed payment plus 50 percent of the additional partnership earnings.
Independent Personal Services
The source of personal services income is the place where the services are rendered. The performance of personal services in the United States usually constitutes a U.S. trade or business. However, tax treaties generally provide exemptions from U.S. tax for nonresidents who work temporarily in the United States. Article 14 of the United States- France Income Tax Treaty provides the rule that an individual or firm of individuals (other than a company) who is a resident of a Contracting State and who derives income from the performance of professional services or other independent activities of a similar character will be exempt from tax in respect of that income by the other Contracting State unless certain conditions are satisfied. The income may be taxed in the other Contracting State if the person has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities and the income is attributable to that fixed base.
Dependent Personal Services
To reflect international law and practice, Article 15 exempts income earned from the performance of certain services. To facilitate international education opportunities, Article 15 provides that payments received for maintenance, education or training by students and apprentices, payments received by professors, teachers, and research scholars, and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State.
Article 15(2) of the United States- France Income Tax Treaty provides that remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: 1) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month period; 2) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and 3) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
Dividends
Article 10 of the U.S.-France Income Tax Treaty provides favorable dividend rates. Such dividends may be taxed in the contracting State of which the company paying the dividend is a resident, and according to the laws of that State, but if the beneficial owner of the dividends is a resident of of the other Contracting State, the tax so charged shall not exceed: (a) 5 percent of the gross amount of the dividend if the beneficial owner owners 1) directly, at least 10 percent of the voting power in the company paying the dividends, if such company is a resident of the United States; or 2) directly or indirectly, at least 10 percent of the capital of the company paying the dividends, if such company is a resident of France. (b) 15 percent of the gross amount of the dividends in other cases.
However, Article 10(3)(a) provides for the elimination of withholding tax on dividends beneficially owned by a company that has owned, directly, or indirectly through one or more residents of either Contracting State, 80 percent or more of the voting power of the company paying the dividend for the 12-month period ending on the date entitled to the dividend is determined. The determination of whether the beneficial owner of the dividends owns at least 80 percent of the voting power of the company is made by taking into account stock owned both directly and indirectly through one or more residents of either Contracting State.
Eligibility for the elimination of withholding tax is provided if a company meets the “publicly traded,” “ownership-base erosion,” and “active trade or business” tests discussed below. According to the technical explanations to the United States-France Income Tax Treaty, these restrictions are necessary because of the increased pressure on the limitation on benefits tests resulting from the fact that the United States has relatively few treaties that provide for such elimination of withholding tax on inter-company dividends. These restrictions are also intended to prevent companies from re-organizing in order to become eligible for the elimination of withholding tax in circumstances where the limitation on benefits provision does not provide sufficient protection against treaty shopping.
For example, assume that ThirdCo is a company resident in a third country that does not have a tax treaty with the United States providing for the elimination of withholding tax on inter-company dividends. ThirdCo owns directly 100 percent of the issued and outstanding voting stock of USCo, a U.S. company, and of FCo, a French company. FCo is a substantial company that manufactures widgets; USCo distributes those widgets in the United States. If ThirdCo contributes to FCo all the stock of USCo, dividends paid by USCo to FCo would qualify for treaty benefits under the active trade or business test described in Article 30 of the United States- France Income Tax Treaty. However, allowing ThirdCo to qualify for the elimination of withholding tax, which is not available to it under the third state’s treaty with the United States, would encourage treaty shopping.
Article 10(5) of the United States- France Income Tax Treaty imposes limitations on the rate reductions in the case of dividends paid by a Regulated Investment Company (“RIC”), Real Estate Investment Trust (“REIT”), Collective Investment Scheme (“SICAV”), Limited Real Estate Investment Companies (“SIIC”), and Societe de Placement a Preponderance Immobiliere a Capital Variable (“SPPICAV”). Article 10(5) provides that a 15 percent maximum rate of withholding tax applies to dividends paid by PICs, SIIC, SPPICAV, RIC, and RIETs provided certain conditions are satisfied.
Interest
Article 11 of the United States- France Income Tax Treaty provides that interest arising in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in the other State. Article 11(3) of the United States- France Income Tax Treaty defines “interest” as income from indebtedness of every kind, whether or not secured by mortgage, and whether or not carrying a right to participate in the debtor’s profits, and in particular, income from government securities and income from bonds or debentures, including premiums or prizes attaching to such securities, bonds, or debentures, as well as other income that is treated as income from money lent by the taxation law of the Contracting State in which the income arises. Penalty charges for late payment are not regarded as interest.
Royalties
Article 12 of the United States- France Income Tax Treaty provides that royalty arising in a Contracting State and paid to a resident of the other contracting State may be taxed in that other State. Such royalty may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner is a resident of the other Contracting State, the tax charged shall not exceed 5 percent of the amount of the royalties. The term “royalties” means:
(a) payments of any kind received as a consideration for the use of; or the right to use, any copyright of literary, artistic, or scientific work or any neighboring right (including reproduction rights, or any software);
(b) payments of any kind received as a consideration for the use of; or the right to use, any patent, trademark, design or model, plan, secret formula pr process, or other like right or property, or for information concerning industrial, commercial, or scientific experience; and
(c) Gains derived from the alienation of any such right or property.
Private Pensions and Annuities
Private pensions have always been taxable at the taxpayer’s residence, always reserving the right of the United States to tax its citizens. A United States citizen residing in France who had worked all his life in the United States would be subject to double taxation on his pension income. France would be subject to double taxation on his pension income. France would tax such income because of residence and the United States would tax it because of source and citizenship. The entire pension would be considered for United States tax purposes as income from sources within the United States because it accrued as a result of United States work and went into a United States fund. The foreign tax credit limitation would likely preclude any foreign tax credit for tax paid to France on the pension. No method is set forth for determining what part of the pension is attributable to a particular country in the event of a working life split between a number of countries, but the fairest and most easily administered system would be on the basis of time, rather than on the basis of contributions.
Alimony and Annuities
Two items of income which the treaty does not mention are alimony and annuities received by a United States citizen or resident residing in France. Under the United States- France Income Tax Treaty, alimony and annuities are taxable only in the state of residence, but the United States retains the right to tax its citizens on them. Thus, both the United States and France have the right to tax these items to dual tax residents residing in France.
Social Security and Pensions
Article 18 of the U.S.- France Income Tax Treaty provides that Social Security and pension payments derived and beneficially owned by a resident of a Contracting State in consideration of past employment, whether paid periodically or in a lump sum, shall only be taxable in that State. In other words, Social Security and Pension payments paid from one country of residence of the other country may be taxed only in the country where the payment originated. Most income tax treaties, including the U.S.-France Income Tax Treaty contains a provision known as a “savings clause.” A “savings clause” prevents a U.S. person from utilizing the provisions of a tax treaty in order to avoid taxation of income. The “savings clause” is found in Article 29 of the U.S.-France Income Tax Treaty. Article 29 of the treaty exempts Article 18 (pensions) from the “savings clause.” Article 18 of the U.S.-France Income Tax Treaty could be very beneficial to U.S. persons that receive a French pension or other retirement arrangement.
Article 24- Special French Tax Benefits for U.S. Citizens Residing in France
Under Article 24, U.S. citizens who meet the treaty test of “residency in France” are excluded from paying French tax on U.S. investment income (interest, royalties, capital gains). This is a courtesy that the French government extends to U.S. citizens (resident in France) with respect to certain U.S. source income from dividends, capital gains, and royalties. Note that this is not an “exclusion” of U.S. investment income from the calculation of France taxable income. Rather it is a tax credit that France offers which ensures that U.S. citizens in France will not pay French tax on that U.S. source investment income.
Branch Profits Tax
The U.S. branch profits tax imposes a tax equal to 30% of a foreign corporation’s dividend equivalent amount for the taxable year, subject to treaty reductions. The dividend equivalent amount estimates the amount of U.S. earnings and profits that a U.S. branch remits to its foreign home office during the year. The branch profits tax is typically 30 percent. Article 10(9) of the treaty limits the branch profits tax to 5 percent.
Foreign Tax Credit Limitation
Internal Revenue Code Section 1411(a)(2) imposes a tax for each tax year equal to 3.8% on net investments. A U.S. taxpayer living abroad is not entitled to take a foreign tax credit against his or her net investment income under the provisions of the treaty.
Limitation on Benefits
In order to qualify for the benefits under an income tax treaty, a foreign individual or entity must not only be a resident of one of the countries party to the treaty, but also satisfy additional restrictions set forth in a Limitation of Benefits (“LOB”) article contained in the treaty. LOB articles have arisen in tax treaties to curtail the practice of “treaty shopping.” In the corporate context, most treaties deem a corporation that is organized under the laws of the country party to the bilateral treaty as a resident of that country. Historically, being a resident of a contracting state was all that was needed for a corporation to claim treaty benefits. This single requirement, together with the relative ease with which corporations could be formed and operated under the laws of many jurisdictions, led companies to form corporate entities in a third country specifically chosen to take advantage of that country’s favorable tax treaty. For this reason, LOB articles require a corporation who is a resident of a contracting state to also satisfy one of the article’s corporate tests before such corporation can claim benefits under the treaty. Among these tests are the “publicly traded company test,” the “ownership-base erosion test,” and the “derivative benefits test.” A corporate resident needs to meet only one of these tests. The tests are generally designed to ensure that there is sufficient nexus between the corporation and its country. The U.S- France Income Tax Treaty’s LOB is contained in Article 30.
LOB Corporate Tests under the U.S.- France Income Tax Treaty
Under the publicly traded company test, a corporation must be a “publicly traded company” which is defined as a corporation whose principal class of shares is “regularly traded” on one or more recognized stock exchanges and either 1) such shares are also primarily traded on one or more recognized stock exchanges located in the contracting state where the corporation is a resident or 2) the corporation’s primary place of management and control is in the contracting state where the corporation is a resident.
The second test, referred to as the ownership-base erosion test, consists of two parts, both of which must be satisfied. The first part addresses the composition of the corporation’s owners and requires that at least 50 percent of the aggregate voting power and value of the corporation’s shares be owned, directly or indirectly, by owners who are residents of the same contracting state where the corporation is a resident. These owners must own their shares in the corporation for a period of time equal to at least one-half of the corporation’s taxable year, and each such owner must be either an individual, a contracting state (or subdivision), a publicly traded company, or a qualified pension fund or tax-exempt organization. The second part of the ownership-base erosion test addresses erosion of the corporation’s tax base. Specifically, this second part provides that certain payments made by the corporation in the taxable year must not total 50 percent or more of its gross income for such year. A payment is subject to this 50 percent limitation if it is deductible for tax purposes in the contracting state where the corporation is a resident and if such payment is made by the corporation to a restricted recipient. Restricted recipients include 1) recipients who are not residents of either contracting state and are not entitled to the benefits of the treaty as an individual, a contracting state (or subdivision), a publicly traded company, or a qualified pension fund or tax-exempt organization and 2) recipients who are connected to the corporation (by at least a 50 percent ownership interest) and benefit from a special tax regime with respect to the deductible payment. The payments limited by this second part of the test do not include arm’s-length payments made in the ordinary course of business for services or tangible property.
The third test is the derivative benefits test. Its purpose is actually to expand treaty benefits to a corporate resident in either contracting state with respect to an item of income. This test applies to closely held corporations that cannot otherwise qualify for treaty benefits to obtain treaty relief. Similar to the ownership-base erosion test, the derivative benefits test also consists of two parts, both of which must be satisfied. The first part requires at least 95 percent of the aggregate voting power and value of the corporation be owned, directly or indirectly, by seven or fewer shareholders who are equivalent beneficiaries. An “equivalent beneficiary” is a person who is the resident of another country that has entered into its own bilateral income tax treaty with the U.S. and who is entitled to the benefits of that other treaty as either an individual, a contracting state (or subdivision), a publicly traded company, or a qualified pension fund or tax-exempt organization within the meaning of the other treaty. However, the benefits afforded to the person by the other treaty (or by any domestic law or other international agreement) must be at least as favorable as the ones afforded by the current treaty under which the person is an equivalent beneficiary. For example, if the other treaty subjects the person to a rate of tax on dividends, interest, or royalties that is higher than the rate applicable under the current treaty, then the person would be disqualified from being an equivalent beneficiary under the current treaty.
The second part of the derivative benefits test mirrors that of the ownership-base erosion test in that it too limits the corporation’s payments that are deductible for tax purposes in the contracting state where the corporation is a resident to be less than 50 percent of its gross income for the taxable year. However, the second parts of both tests differ in who they define to be a restricted recipient of the deductible payment. In the case of the derivative benefits test, restricted recipients include 1) recipients who are not equivalent beneficiaries, 2) recipients who are equivalent beneficiaries only because they function as a headquarters company for a multinational corporate group consisting of the corporation and its subsidiaries, and 3) recipients who are equivalent beneficiaries that are connected to the corporation (by at least a 50 percent ownership interest) and benefit from a special tax regime with respect to the deductible payment. Like the ownership-base erosion test, the payments limited by this second part of the test do not include arm’s-length payments made in the ordinary course of business for services or tangible property.
“Equivalent Beneficiaries” under the Derivative Benefits Test
The following U.S. – France Income Tax Treaty contains a derivative benefits provision in its LOB articles.The U.S.- France Income Tax Treaty broadly allows residents of any jurisdiction that has an income tax treaty with the U.S. to be treated as equivalent beneficiaries.
Disclosure of Treaty-Based Return Positions
Any U.S. taxpayer that claims the benefits of a treaty (such as the United States- France Income Tax Treaty) by taking a tax return position that is in conflict with the Internal Revenue Code must disclose the position. See IRC Section 6114. A tax return position is considered to be in conflict with the Internal Revenue Code, and therefore treaty-based, if the U.S. tax liability under the treaty is different from the tax liability that would have to be reported in the absence of a treaty. A taxpayer reports treaty-based positions either by attaching a statement to its return or by using Form 8833.
The Income Tax Regulations describe the items to be disclosed on a Form 8833. The disclosure statement typically requires six items:
1. The name and employer identification number of both the recipient and payor of the income at issue;
2. The type of treaty benefited item and its amount;
3. The facts and an explanation supporting the return position taken;
4. The specific treaty provisions on which the taxpayer bases its claims;
5. The Internal Revenue Code provision exempted or reduced; and
6. An explanation of any applicable limitations on benefits provisions.
Anthony Diosdi is an international tax attorney at Diosdi & Liu, LLP. Anthony focuses his practice on providing tax planning domestic and international tax planning for multinational companies, closely held businesses, and individuals. In addition to providing tax planning advice, Anthony Diosdi frequently represents taxpayers nationally in controversies before the Internal Revenue Service, United States Tax Court, United States Court of Federal Claims, Federal District Courts, and the Circuit Courts of Appeal. In addition, Anthony Diosdi has written numerous articles on international tax planning and frequently provides continuing educational programs to tax professionals. Anthony Diosdi is a member of the California and Florida bars. He can be reached at 415-318-3990 or adiosdi@sftaxcounsel.com.
This article is not legal or tax advice. If you are in need of legal or tax advice, you should immediately consult a licensed attorney.
Anthony Diosdi is one of several tax attorneys and international tax attorneys at Diosdi Ching & Liu, LLP. As a domestic tax attorney and international tax attorney, Anthony Diosdi provides international tax advice to individuals, closely held entities, and publicly traded corporations. Diosdi Ching & Liu, LLP has offices in San Francisco, California, Pleasanton, California and Fort Lauderdale, Florida. Anthony Diosdi advises clients in international tax matters throughout the United States. Anthony Diosdi may be reached at (415) 318-3990 or by email: adiosdi@sftaxcounsel.com.
This article is not legal or tax advice. If you are in need of legal or tax advice, you should immediately consult a licensed attorney.