Investor Use Cases
- Individual, corporation or trust with taxable investment portfolio income
- Charitable Lead Annuity Trust (CLAT) with phantom income
- Business owner contemplating a future sale of the business
- Business owner with business operating income
- Hedge fund manager with "carried interests"
- ETFs, Institutional funds, and other pooled interests
- Captive Insurance Companies (CICs)
- Passive Foreign Investment Companies (PFICs)
- Individual or family with a Private Foundation
- Recipient of large settlement proceeds
- Business owner contemplating an IPO
- FIRPTA: Non-US Citizen Investor in US Real Property
- ECI: Non-US Citizen with US "Effectively Connected" Trade or Business Income
- Puerto Rico Act 60 Beneficiary with "US Source Income"
- USVI EDC Beneficiary with "US Source Income"