ARGENTINA-TEXAS

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  • 20 Aug 2019 4:22 PM | Lucas Lombardi (Administrator)
    We invite you all to be part of the 2019 ATCC webinars educational series!
    This is a unique opportunity to get great visibility by providing powerful and meaningful information to our +13,000  member community.

    Examples:
    • US or Argentina Macro View
    • How to do business in the US, Texas and/or Argentina        
    • Industry or Business Sector Insights (Oil and Gas, Renewable Energy, Technology, Logistics, etc.)
    • Entrepreneurial Case Studies or Success Stories
    • Tax, Legal, Immigration, Translation, Accounting information/guidance.
    • Interviews with key leaders 
    • Instructions or How-Tos
    Conditions:
    • Aligned with ATCC mission
    • English or Spanish
    • 20 min presentation + 5 min Questions and Answers section
    • Must have a Powerpoint presentation (it may be sent to the audience after the presentation if presenter authorizes). You will have to use the ATCC PowerPoint Master
    • No selling any products or services
    • Author Full Name, Company, and Logo (and link) 
    • 6 alternative tentative presentation dates between August and December 2019
    The ATCC provides the webinar tool (WebEx)
    The webinar will be live and can hold up to 200 attendees. We will record the webinar, put it on our web and promote it through our emailing and socials networks.

    The ATCC Marketing committee will select the webinars and coordinate details with the author. 
    If you want to be a speaker in our webinar series write us to marketing@argentinatexas.org

    Thanks in advance for your participation,

    ATCC - Marketing Commission


  • 20 Aug 2019 3:37 PM | Lucas Lombardi (Administrator)

    Opportunity Zones: doing well by doing good

    An opportunity zone, located in an economically distressed community, spurs investments via preferred tax treatment.

    The IRS describes an opportunity zone as "an economically-distressed community where new investments, under certain conditions, may be eligible for preferential tax treatment." How does a community become an opportunity zone? Localities qualify as opportunity zones when they've been nominated by their states. Then, the Secretary of the U.S. Treasury certifies the nomination. The Treasury Secretary delegates authority to the IRS.

    The Tax Cuts and Jobs Act added opportunity zones to the tax code. The IRS says opportunity zones are new, although there have been other provisions in the past to help communities in need with tax incentives to spur business.

    The new wrinkle is how opportunity zones are designed to stimulate economic development via tax benefits for investors.

    • A Qualified Opportunity Fund is an investment vehicle set up as a partnership or corporation for investing in eligible property located in a qualified opportunity zone. A limited liability company that chooses to be treated either as a partnership or corporation for federal tax purposes can organize as a QOF.
    • Investors can defer taxes on any prior gains invested in a QOF until whichever is earlier: the date the QOF investment is sold or exchanged or Dec. 31, 2026.
    • If the QOF investment is held longer than five years, there is a 10 percent exclusion of the deferred gain.
    • If the QOF investment is held for more than seven years, there is a 15 percent exclusion of the deferred gain.
    • If the QOF investment is held for at least 10 years, the investor is eligible for an increase in basis on the investment equal to its fair market value on the date that the QOF investment is sold or exchanged.
    • You don't have to live, work or have a business in an opportunity zone to get the tax benefits. But you do need to invest a recognized gain in a QOF and elect to defer the tax on that gain.
    • To become a QOF, an eligible corporation or partnership self-certifies by filing Form 8996, Qualified Opportunity Fund, with its federal income tax return.

    The first set of opportunity zones covers parts of 18 states and was designated on April 9, 2018. Since then, there have been opportunity zones added to parts of all 50 states, the District of Columbia and five U.S. territories. More details are available on the U.S. Treasury website.

    DISCLAIMER

    This communication is not intended to be tax advice and should not be treated as such. Readers should contact your tax professional to discuss your specific situation.

    Oscar Eduardo Mary is a founding member of RCBM, an international tax and business consulting firm headquartered in Buenos Aires, Argentina and with a branch office in Carrollton, Texas. RCBM assists companies that want to operate in Argentina and / or United States. You may contact him at o.mary@rcbmgroup.com


  • 20 Aug 2019 3:16 PM | Lucas Lombardi (Administrator)

    The annual turnaround is one of the most critical activities of the year, and still companies usually hire hundreds of unknown contractors from different companies. How can you manage to reduce the odds of a safety incident?

    Safe + Sound Week is August 12-18. It is a nationwide event held each August that recognizes the successes of workplace safety and health programs and offers information and ideas on how to keep America's workers safe. I Figured it was a great opportunity to talk about safety during an annual turnaround.

    When an annual turnaround is approaching, it is crucial to foresee the number of contractors that your company will be dealing with, and define a plan to align safety practices. Still, a 100% compliance rate is almost impossible considering that contractors don’t have the same culture employees have, they are trained with different habits and behaviors that are hard to transform in only 10-20 days. We usually underestimate the communication gap we have with them, which is normally the root cause for near misses and accidents.

    Common approaches to reduce accidents

    One of the most common approaches to reduce accidents is to make every contractor pass a safety training previous to working in the facility, to ensure a common understanding of various safety aspects. Other common approaches are sharing digital safety manuals and holding regular meetings before and during the outage with the contractor’s representative. The problem is that these type of training sessions or meetings don’t usually dig deeper on some typical problems, like dealing with: extreme weather conditions, work delays, language barriers, exceptions and other one-time events that may come up.

    How can you work to reduce this communication gap?

    I agree it is impossible to cover everything in a meeting, a training session or a manual. I propose on top of them, to adopt some of the following best practices to help you bridge the gap and be on top of the problems at any particular time during the outage.

    Leading safety by walking around

    There is nothing more effective than seeing things by yourself. First-hand knowledge is the highest form of information. Normal practice is to have the owner of the process or the engineer visiting the site at the beginning of the shift to sign the job safety analysis. Even though pre-job observations are effective, they are rarely reviewed during the day, they are merely seen as part of the bureaucracy. Safety advocates, as well as engineers and managers, should get more involved in the job, observing regularly how work is being done, asking questions and detecting problems at the gemba (where the action occurs, in Japanese).

    Attending toolbox meetings

    Toolbox meetings are meetings held by contractors or employees at the beginning of the shift. The benefit of attending to them is the possibility to talk and listen to the entire crew, while during the day they are all busy working on different machines. It can be used to communicate safety incidents, refresh on safety topics and listen to the contractor’s concerns. Sometimes the concerns are not discussed with the crew supervisor, but building a close relationship with the employees directly could help gather more inside information to help the safety team prevent issues. Make sure to adapt your own meeting schedules to accommodate for these meetings.

    Dedicating full-time safety advocates

    In order to ensure all groups are covered and receive the same type of information across the board, some companies hire full-time safety advocates during the outages. This person is in charge of making sure the specific safety practices for the outage are followed, not by attending a seminar, but by observing contractors at work. They are also in charge of tackling specific concerns, like how to react to specific weather conditions, sharing company values and expectations for this outage in particular or answering specific job-related questions.

    Using visual management tools to communicate housekeeping practices

    When housekeeping is not a good practice for the employees, contractors are not going to be better, period. So if you want to keep the plant in good standing during the outage, avoiding tools, machine parts and boxes to become safety hazards, start at home. Training the employees to keep the workplace organized at any time, using signs and colors to communicate where are the trash cans and hoppers located and where tools, restrooms or emergency exits can be found is part of the pre-outage effort.

    Planning for weather conditions

    When work is done outside is when weather conditions can mostly impact the outcome and duration of the outage. Planning weather conditions in advance is extremely important. Some questions that for sure will rise are: should work be stopped with rain, with snow or with lightning? With extremely hot weather, be prepared to rent cooling stations, fans, provide water and Sqwinchers or electrolyte beverages, and again, have the safety advocate encouraging proper rest and hydration. Communication in these situations is key.

    Considering language barriers

    You may know and communicate well with all your employees, but communication with contractors can be very different. Especially language barriers are important to consider, as contractors and experts can come from different regions and locations. In Texas, for example, the number of Hispanic speaking contractors in an outage can be as high as 30-40%. It is a must to make sure that signs, manuals, training and continuous onsite communication are 100% understood by everybody. Never assume that because someone lives in the US, speaks or reads perfect English.

    Conclusion

    These 6 tips are essential to make the most out of your outage planning. Yet it is never enough. I would like to repeat and highlight the last piece of advice, which is: never ever assume anything. Again, you can never plan for everything, so being vigilant, open-minded and taking nothing for granted is important to detect and prevent issues before they get worse. When attending tool box meeting for example, many times I realize when a group is not communicating well, is having discipline issues or the team members don’t have the right support. Always be ready for the unexpected!

    If you would like to learn more about hiring a safety advocate, contact us to learn more.

    @lupaulise

    luciana@biztorming.com


  • 23 Jul 2019 12:57 PM | Lucas Lombardi (Administrator)

    Reviewing Your Business Structure After the Tax Cuts and Jobs Act

    Business structure matters. If you plan on starting a small business, you will have to choose how it will be legally organized. This decision has been made a little more complex as a result of federal tax law changes made by 2017's Tax Cuts and Jobs Act (TCJA). In fact, even owners of companies that have been operating for some time may want to evaluate whether their existing business structure puts them in the best position to benefit from the tax law changes.

    C Corporations and Lower Corporate Taxes
    Traditionally, owners of small businesses organized as C corporations have faced a potential double taxation issue. The corporation pays taxes on its profits, and if those profits are distributed to the owners as dividends, the dividends are taxed to the owners individually. Because dividends are not tax deductible by the corporation, corporate profits are essentially taxed twice. Prior to the TCJA, C corporations paid federal income taxes on a graduated scale up to 35% of taxable income. Personal service corporations paid taxes at a flat 35%. The TJCA reduced the corporate income tax rate substantially to a flat 21%. The corporate tax rate reduction is a significant benefit for C corporations and their owners. Moreover, a C corporation can fully deduct state and local income taxes, whereas the TCJA limits an individual taxpayer's itemized deduction for state and local taxes to $10,000 ($5,000 if married filing separately).

    Pass-Through Entities
    Generally, the net taxable income from pass-through entities -- S corporations, partnerships, limited liability companies (LLCs) taxed as sole proprietorships or partnerships, and sole proprietorships -- is taxed to the owners individually at their regular income tax rates. With limited exceptions, a corporatelevel tax does not apply. The TCJA lowered the top regular income tax rate for individual taxpayers from 39.6% to 37% through 2025. Additionally, thanks to the TCJA, individuals who own interests in pass-through business entities may be eligible to deduct up to 20% of their qualified business income. The 20% deduction is subject to significant limitations that apply to owners at higher income levels. However, for business owners who can qualify, the 20% deduction lowers the top effective tax rate on their qualified business income to 29.6%.

    To Switch or Not?
    The 21% corporate income tax rate may prompt small business owners to consider switching to (or starting) a C corporation. There are various factors to weigh before making a decision. For example, switching to a C corporation may make more sense for companies that expect to reinvest capital for business needs than for companies that intend to distribute profits to shareholders in the form of taxable dividends. However, should the owners contemplate a future sale of the business, double taxation would still be a potential issue were the transaction to be structured as an asset sale.

    Professional Advice Is Necessary
    This is a complex issue and there are numerous variables -- both tax and nontax -- that will come into play. Be sure to consult your legal and tax advisors before making a move to switch to a different business structure or to select an entity type for a new business.

    DISCLAIMER
    This communication is not intended to be tax advice and should not be treated as such. Readers should contact your tax professional to discuss your specific situation.

    Oscar Eduardo Mary is a founding member of RCBM, an international tax and business consulting firm headquartered in Buenos Aires, Argentina and with a branch office in Carrollton, Texas. RCBM assists companies that want to operate in Argentina and / or United States. You may contact him at o.mary@rcbmgroup.com

    RCBM GROUP logo



  • 23 Jul 2019 12:48 PM | Lucas Lombardi (Administrator)

    Early hydraulic fracturing completions in the Vaca Muerta Formation in central Argentina have traditionally incorporated the use of conventional fluid systems, such as linear and crosslinked guar-based polymers. Within the past few years, however, the benefits of viscosifying friction reducers (HVFR) have been demonstrated in the industry, predominantly within the United States. These benefits include cost savings, simplified operations and enhanced well production. Recently, a major Argentinian operator successfully trialed the HVFR technology in the Vaca Muerta Formation.

    Image result for Neuquén Basin in Central Argentina

    Neuquén Basin in Central Argentina

    The Technology

    HVFR fluid systems are polyacrylamide-based polymers that are commonly used as friction reducers for fracturing. Some of these polymers can develop viscosity with higher concentrations and are very good at transporting proppant out into the fracture network. Unlike guar-based fluids, the HVFR fluids contain no residue and provide excellent cleanup after fracturing. Operationally, the fluids are very simple to use and require no hydration equipment or complex chemical additives.

    The Field Trial

    The pilot project was performed on a horizontal, 27 stage lateral in the Aguada Pichana Oeste field in the Neuquén Basin of Argentina. Positive laboratory test results led to a field trial, during which several benefits of the HVFR fluid system emerged. Operational efficiency was an early success, including a reduction in the quantity of chemicals on location, more simplified pumping schedules, and low pumping pressures. Secondly, significant cost savings were realized compared to previous fluid system packages. Finally, positive production results were observed, leading to the decision to incorporate this technology into full field development operations.

    The performance of this relatively new treatment fluid delivered positive results in a strategic international asset. The project has led to full field development using this technology.

    by Mark Van Domelen
    Vice President – Technology
    Downhole Chemical Solutions logo


  • 23 Jul 2019 12:42 PM | Lucas Lombardi (Administrator)

    An innovative and safe hydraulic control system

    Designed by the Argentinian company Moto Mecanica Argentina SA. (MMA), and with the project leadership of Cristian Decia, the “mSafe” was introduced as a self-contained hydraulic control system that incorporates electronic assistance which allows operators to open and securely close a hydraulic valve, operated locally, remotely and automatically by high or low pressure in the line or ESD.

    What is it used for

    The control system provides safe and controlled oil and gas wells operations. It also contributes to the well-being of the environment since it is compatible with solar panels. The battery feeds the electronic control demand; an electro-hydraulic pump that is responsible for providing the flow and pressure required by the hydraulic actuator of the valve to keep it open. For the closing, it has a solenoid valve that is integrated into the electro-hydraulic pump that causes the pressure of the actuator to fall, ending in the closing of the valve.

    How does it work and benefits

    The mSafe has a pressure stabilization actuator system by daily temperature variation. It provides and relieves hydraulic fluids automatically to maintain a stable pressure inside the actuator of the valve within a pre-set range. This function eliminates progressive closure that occurs in purely mechanical systems which require continuous operator intervention.

    According to the client’s request, the mSafe can carry out programmed and systematic “Partial Stroke Test” for the valve. This allows the operator to anticipate small anomalies in operations. Some of the benefits of the system include the reduction of operating expenses due to the lower amount of visits to the well. It also facilitates the installation, and it requires low maintenance.

    Locations in use

    The equipment has been used in the wells of Eagle Fort and Barnett, both located in Texas. Eagle Fort is possibly one of the largest single economic developments in the history of the state. It has also been used in wells of Bakken Three Forks, located in North Dakota.

    Conclusion

    The mSafe has been proven to be an efficient method to stabilize the pressure inside an actuator of a valve without using hydraulic accumulator (hydraulic accumulators may be dangerous because they contain a very high pressure of nitrogen), and allows the user to manage the equipment from the distance. It can also be helpful to prevent any irregularity or damage in operations.


    This report was written by Cristian Decia, Director and Automation and Control Manager of

    MMA - MOTO MECÁNICA ARGENTINA S.A. 

    For more information visit the following link: https://drive.google.com/file/d/1lYO4p8FXdPdd3nyj3EYbQ6whlGCyNGTc/view?usp=sharing

    or visit the following website:
    www.motomecanica.com


  • 23 Jul 2019 12:31 PM | Lucas Lombardi (Administrator)

    Over the past 6 years we have been reading, investigating, engaging and plotting ideas around the potentialities of combining technical solutions. It is indeed an exercise that many major consulting firms have been undertaking proposing potential futuristic scenarios. What in our perspective is sometimes lacking is the description of the path to go from today to the future: this is what we call the “NEXT” step!! Building upon the ideas and topics discussed in our previous posts on Disruptive Energy and Intelligence of Things, it is our fundamental strategic pillar at Bridging Value. So let me walk you to an interesting exercise of convergence.

    Wireless Electricity

    Aren’t you all tired of having to desperately look for a plug to charge your phone? Don’t you grow with the terror of your toddlers plugging some metallic object by chance in the “only” outlet you forget to protect? What about being regularly concerned about tripping over an extension cord while walking around the house? And at last, why our cities are full of those unaesthetic poles with cables running in every directions? Some of these frustrations were channeled to create WiTricity: a Massachusetts-based start-up designing solutions to wirelessly charge various appliances. The base technology is magnetic resonance. Indeed, in their early stages, their focus was on unwiring every possible appliance. In past few years though they targeted automotive batteries, betting on BEV’s for the future of mobility.

    At present, England and South Korea have been experimenting with direct solutions into their local markets particularly with respect to public transportation.

    In England the Highway administration after having announced in 2014 a plan to pilot wireless charging in certain segments of their network, has launched in 2018 a “£40 million for projects that look at creating public areas to charge electric cars or wireless charging for commercial vehicles” In the meantime, in Milton Keynes, 8 Arriva buses are regularly wirelessly charging their batteries. South Korea, in 2013, pioneered wireless bus charging in Gumi, as reported by the WSJ and other media outlets. And as recently as February 2019, Transport As A Service (TAAS) Magazine inform us that Yura Corporation established a technology license agreement with WiTricity.

    Human Power

    Do you recall the whole Jamaican Sweep 200-meter dash finishing lead by Usain Bolt? What about Phelps vs. Lochte? Well, during the London Summer Olympics in 2012, a new technology was being piloted in the City; precisely at the West Ham tube walkway. Pavegen has since gone through multiple product iterations and design adjustment that allowed it to conquer multiple public spaces from the Abu Dhabi airport to Dupont Circle in Washington DC. Humans are regularly transferring energy while walking and in a constantly more urbanized world this trend will naturally increase, further accelerated by the need of staying active. 3 Pavegen unit cells can continuously light a 100-W Equivalent LED bulb; that means that in densely populated area where people walk streets could be independently lit.

    It goes without saying that I am already starting to imagine multiple areas that might benefit from installing the Pavegen or equivalent solution: Hotels, Supermarkets, Parking lots, Airports, Dancing clubs, major Road Crossings, Train Stations, Hospitals, Convention Centers and Stadium


    Wherever we are active, we are transferring energy hence we are generating power

    The Convergence

    WiTricy or Pavegen or any other company that might come to mind, alone would not be able to address the complex energy problems we are facing; honestly, I do not think they even want to take on that challenge. What if though we lay out complex problems and then after a process of “de-structuring complexities” we address each item as part of a broader vision?

    Well, in this case, imagine taking off from your nearest airport and landing in Rome Fiumicino, Italy, (43M yearly passengers) catch the train line to the main station Termini (2.3M sqft // approx 480K daily visitors // 150M yearly visitors) to hop on bus line 64 to head to the Vatican Museums (6.4M yearly visitors) and stare in awe to the Sistine Chapel Frescos.

    Along this journey, we can identify key nodes where to collect Human Power and Wirelessly recharge energy improve the over all human experience. As the axle of the Roman Chariots defined the modern railway gauge, iconic integrated projects will impact the future of our living experiences. Hence, designing an environment while facilitating the human interfaces will offer opportunities that where just fictional few years ago.

    We at Bridging Value are constantly imagining future scenarios, proposing solution roadmaps by establishing strategic technical partnerships.


    By Giuseppe Liberati, GM and Chief Strategist at
    Bridging Value LLC logo

  • 1 Jul 2019 12:12 PM | Lucas Lombardi (Administrator)

    Dear Participants of the ATCC Anniversary,

    We would like to express our heartfelt thanks to each of you who participated in ATCC 3rd Anniversary. Over 120 persons gave their time to attend ATCC Anniversary. 

    Hopefully you enjoyed the social program and that you used the opportunity to extend your existing networks. We are sure that the cooperation with most of you will continue in the near future.

    We would like to give special thanks to Mr. Ali Moshiri and to King & Spalding LLP for hosting us during the event, and furthermore to Our Sponsors;

    Platinum:


    Gold

      

            

    Silver

     

     

    Bronze




    Best wishes,

    ATCC


  • 20 Jun 2019 12:20 PM | Lucas Lombardi (Administrator)

    ATCC President Reflects on Chamber’s First Three Years

    (ATTC President: Victoria Balaban)

    When an organization is founded on a major national holiday, it’s a good sign its founders are sure of their cause and have bright hopes for their new entity’s future. Such is the case with the Argentine-Texas Chamber of Commerce, which was founded three years ago on Argentina’s 25 de mayo holiday, which marks the start of that country’s path to independence from Spain.

    Although the Chamber’s first three years may not have been as momentous as the events that unfolded in Buenos Aires in 1810, there is much to be proud of and plenty to come, according to Chamber president, Victoria Balaban, who is also one of the organization’s founding members.

    “Our first objective is to stimulate synergy between the two regions, but through collaboration with other chambers we are also finding ways to increase our impact,” she said in a recent interview.

    Indeed, the synergy between the two regions is already “Texas-sized.” Trade between Argentina and Houston alone reached a high of 3.7 billion dollars in 2014, though it tapered off somewhat in the following years. The balance is strongly in Houston’s favor, but Argentine companies are making inroads.

    This is one area where the Chamber has expanded its presence, across multiple sectors. As an example, Balaban points to the support ATCC gave to a trade mission to Houston from the American Chamber of Commerce in Argentina to study medical technologies. Among other things, ATCC helped arrange a visit to MD Anderson for the AmCham delegation. The Chamber is now helping arrange the agenda for another AmCham mission in October to explore opportunities in logistics.

    ATCC can also provide valuable support to US companies looking to expand into Argentina. This is especially the case for smaller companies that do not have the resources that larger companies do as they seek to grow their business in new markets.

    “We have a wide range of contacts we can reach out to in business and government in Argentina that can then provide US companies with information and support in getting started there,” commented Balaban. The Chamber is also taking part in organizing a Texas trade mission to Argentina in 2020.

    She added that finding the right opportunity and the right people to work with is critical to any company looking to expand into Argentina, given the country’s political and economic volatility. Her recommendation to any company looking to take that leap: “Be flexible and willing to live with uncertainty. It’s also a good idea to find a local partner or distributor.”

    Despite her words of caution, Balaban is confident that companies that take the right approach and are willing to be patient, can find tremendous opportunities in Argentina. Why? “Because there is everything to be done,” she responded.

    And those opportunities go well beyond the energy sector and the much vaunted Vaca Muerta formation, home to one of the world’s richest deposits of shale gas and oil, which has already captured billions of dollars in foreign investment. Other sectors that offer great potential include real estate, health care, information technology and services, like legal and accounting services. Yet another is Fintech (technology applied to financial transactions), given Argentina’s low rate of bancarization.

    As much as ATCC has accomplished and hopes to accomplish, it is still a small organization that depends on the volunteer efforts of Balaban and other members. So, to boost its impact the Chamber often collaborates with other chambers – from the Brazil-Texas Chamber of Commerce to the Russia-Texas Chamber of Commerce – to co-sponsor events or activities. Such was the case with a cocktail 10 chambers combined organized in May on the evening before the start of the energy sector’s mega-event in Houston, the Offshore Technology Conference. More than 330 persons attended the cocktail.

    Looking ahead, Balaban said ATCC’s objective is to continue building on the successes of its first three years and expand its membership. With the two regions having so much in common, like a strong presence in natural resources industries, and Texas being home to a large Spanish-speaking population, the potential is enormous.

    “I think the fact that we have a 95% renewal rate on memberships shows that the Chamber can add real value to people and companies looking to do business between the two regions,” she said. And much like investors eyeing Argentina she is confident that there is still so much to do.


  • 19 Jun 2019 12:55 PM | Lucas Lombardi (Administrator)

    Taxation on Limited Liability Companies (LLCs)

    LLCs are a creation of state law. LLCs are owned (and in some cases managed) by members who aren’t personally liable for the LLC’s debts or obligations.
    Under the “Check-the-box” entity classification rules, if an LLC isn’t mandatorily classified as a corporation, it’s an “eligible entity” that may elect to be classified for tax purposes either as a partnership or as a corporation, except that a single-member LLC that doesn’t elect to be a corporation is treated as a disregarded entity and its activities are treated in the same manner as a sole proprietorship, branch or division.
    Partnerships are “pass-through entities” -that is, their income is subject to tax only once, at the partner level. They share this characteristic with S-corporation, but not Ccorporations (whose income is taxed twice, once at a corporate and again at the shareholder levels). Partnerships offer several advantages over S-corporations, including no limitation on the identity or number of partners; greater flexibility in allocating the enterprise’s profits, losses and credits and a partner’s basis in his partnership interest includes the partner’s share of partnership liabilities.
    In general, no gain or loss is recognized when a partner makes contributions to a partnership’s capital, whether made on formation of the partnership or later.

    Partnership Income and Deductions

    A partnership is essentially a conduit that passes through to each partner his or her share of income and deduction generated by the partnership. Thus, the partner, not the partnership, are taxed on the partnership’s income. The partnership only files an information return showing each partner’s distributive share of the partnership income, deductions, gains, losses, etc. Each partner includes his/her share of these items on his own return.
    Partnership taxable income is computed the same as an individual’s, except that certain items are separately stated, and certain deductions aren’t allowed. Each item passed through to the partners and separately stated on their returns has the same character as if realized or incurred directly by the partnership.
    Each partner reports his distributive share of the partnership income, deductions and other items (including guarantee salary and interest payments) for a partnership tax year on his/her individual return for his/her tax year with or within which ends the partnership tax year.

    TAX Withholding on Payments to Foreign Taxpayers

    Several withholding regimes enforce the imposition of tax and/or reporting requirements on foreign taxpayers. These include withholding at a 30% or lower rate on the gross amount of effectively connected income of foreign partners in a partnership. Nonresident alien individuals, foreign partnerships or corporations, and any other person that it is not a U.S. person are subject to withholding.
    A partnership must pay a withholding tax if it has “effectively connected taxable income” for the tax year (whether or not the income is distributed), any part of which is allocable to a foreign partner. Unless the partner can show that the tax should be lower, the partnership must withhold at the highest rate of U.S. (corporate or individual, as applicable) tax to which the foreign partner would be subject on that allocable income.
    The partnership must pay the withheld amount in four installments, report the partnership’s total withholding liability for its year to the IRS, and notify each foreign partner of his/her share thereof.

    Disclaimer

    This communication is not intended to be tax advice and should not be treated as such. Readers should contact your tax professional to discuss your specific situation.

    Oscar Eduardo Mary is a founding member of RCBM, an international tax and business consulting firm headquartered in Buenos Aires, Argentina and with a branch office in Carrollton, Texas. RCBM assists companies that want to operate in Argentina and / or United States. You may contact him at o.mary@rcbmgroup.com.


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ABOUT

The Argentina Texas Chamber of Commerce is the primary advocate of Argentina and Texas business communities and is dedicated to building economic prosperity for both Countries. The Chamber of Commerce is a Member-driven organization.

CONTACTS

5100 Westheimer Rd, Ste 200

Houston, TX 77056

United States

Phone:  +1 (713) 969-5036

Fax: +1 (713) 966-6125

info@argentinatexas.org

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