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WebInbound Transactions & US International Tax Contents [ hide] 1 Inbound Transactions & US International Tax 2 Nonresident Investment into the United States 3 FDAP (Fixed, Determinable, Annual and Periodic) 4 ECI (Effectively Connected Income) 5 Common Types of Income from Inbound Transactions 6 Election from FDAP to ECI for Inbound … WebAs part of our inbound tax planning services, we: Helped them understand the implications of various types of US business structures Prepared projections for them to show how the business owners would be taxed and the type of US tax filings they would need to report WebIn the inbound context, hybrid financing most often is thought of as an arrangement that is treated as debt for U.S. federal tax purposes but equity for non-U.S. federal tax purposes. In comparison with a loan in the … shanti exim international pvt ltd