Analysis, commentary, and practical guidance on the legal issues shaping U.S. - Mexico business.
Annual compliance calendar and filing obligations for Mexican owners of US LLCs, including Form 5472, effectively connected income analysis, and dual-jurisdiction tax reporting requirements.
Practical guide to cross-border search fund acquisitions by Mexican nationals, covering SBA financing restrictions, entity selection, and seller note enforcement across jurisdictions.
Analysis of US estate tax exposure for Mexican nationals holding US assets, including situs rules, the treaty gap, and planning structures to mitigate liability.
Mexican entrepreneurs and founders entering the US market face a foundational decision: what legal structure will hold US operations? This Insight maps the entity selection landscape, examining trade-offs between C-corporations and LLCs, multi-tier holding structures, and cross-border implications.
Framework for QSBS planning and post-exit tax strategies for founders, including cross-border issues with Mexican residents and timing considerations around the liquidity event.
Framework for using standby letters of credit in US-Mexico transactions, including ISP98/UCP 600 mechanics, drafting considerations, and enforcement advantages over traditional guarantees.
Structuring guide for seller-financed notes in cross-border deals, covering UCC Article 9, Mexican security interests, personal guarantees, and enforcement mechanics across jurisdictions.
FIRPTA withholding obligations, the Form 8288-B process, USRPHC status, and coordination with Mexican income tax for sellers of US real property interests.
Guide to choosing between S.A. de C.V., S. de R.L., and SAPI structures for US companies expanding into Mexico, including foreign investment rules and sector restrictions.
Comparison of asset and stock purchase structures for Mexican buyers, addressing tax efficiency, liability allocation, financing implications, and cross-border considerations.
Technical deep-dive into Section 1202 requirements, rollover risks, passive asset creep, and state-specific issues for search fund investors and cross-border entrepreneurs.