All nonresident business entities and individual investors or service providers who have income effectively connected with the conduct of a trade or business within the United States will be, to a lesser or greater degree, affected by the U.S. tax laws and regulations.  An investment made in a U.S. real property interest carries with it its own set of income tax and wealth tax complexities.   It is on you, the company executive or the private investor, to ensure that affected does not become synonymous with afflicted. Your tax planning should start early, i.e., well before the entry on the U.S. market, before formation of an entity in the U.S. under a state law, and before any investment in real property.   

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Cezary Tchorznicki is a licensed Certified Public Accountant in the State of New York.  Cezary held professional positions with the Internal Revenue Service during a career that spanned over 24 years - a career that commenced in 1991 in Los Angeles and ended in 2015 in New York City.

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Over the past eight years, Cezary has advised company executives and individual investors on a number of tax issues, to include choice of entity, permanent establishment, income repatriation, income sourcing rules for digital and cloud transactions, tax consequences of intellectual property transfers, requirements for foreign-owned domestic disregarded entities, tax treatment of hybrid entities, Controlled Foreign Corporation reporting, GILTI reporting, redemption of US partnership interest, and the impact of the U.S. estate and gift tax regime on a foreign real estate investor. He has also assisted clients in a number of compliance and tax controversy related matters.

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Cezary earned a master's degree in taxation from Villanova University and a master's degree in financial management from University of Barcelona. 

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He is a member of the AICPA, the New York State CPA Society, and the Beta Gamma Sigma honor society. 

 

Cezary speaks English, Polish and Spanish (DELE Level C1).