American Offshore Business Tax Planning: Can Australian Lawyers Get a Piece of the Action?

This paper will investigate: (1) a pair of important American offshore income tax planning strategies; (2) opportunities for Australian lawyers to participate in the implementation of those strategies; and (3) opportunities for Australian lawyers to employ those strategies for the benefit of Australian clients. First, however, a brief explanation is required of the US federal approach to taxing business income. Without this explanation, the information in Part III below would invite incredulity.