US Tax Heide Robson

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6 common questions and their answers
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When your clients plan an expansion into the US, they will most likely ask you how to structure this. Should they just trade through their Australian entity? Or set up an entity in the US?
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How you structure into US public and private markets depends on whether you invest for cash flow or capital growth. How should you structure your passive investments in the US? Set up a US entity or trade through your Australian entity?
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There is a sharp distinction between the econcomic nexus for sales tax and the one for state income tax.
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We already mentioned PL 86-272 a number of times in past episodes. Frances Ellington mentioned it and then also Ed Antolin. Today let’s drill deeper because losing the protection that PL 86-272 grants you, can cost you a lot of money in state income taxes. 
While PL 86-272 is federal law and so applies to all 50 states, let’s discuss the technical advice memorandum California’s Franchise Tax Board issued. Because California is trying to limit the application of PL 86-272 and chances are that other states will follow suite.
And just one comment on the side: The state revenue office in California is called the Franchise Tax Board, in short FTB.
The speaker in this episode is Edwin Antolin of Vallejo Antolin Agarwal Kanter, or in short VAAK, in Walnut Creek, California about California’s technical advice memorandum to PL 86-272.

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