International Tax Impact of Business Entity Selection for Foreign Operations of U.S. Companies

When U.S. companies are starting a foreign operation, entity selection poses critical decisions for tax professionals. Is it most advantageous for the company in the long term to choose a branch office? A foreign corporation subsidiary? A joint venture? A check-the-box entity? Each choice has unique tax aspects.

Making that choice requires the tax specialist to assess the U.S. tax issues with disregarded entities, controlled foreign corporations and foreign partnerships. Tax execs must understand all of the tax impacts—pro and con—when foreign base company income and dual consolidated losses are generated.

Given the broad array of decisions in selecting the entity for a foreign business unit, tax professionals must grasp the U.S. tax treatment of all entity and income possibilities.

Listen as our tax adviser panelists offer practical analysis of tax and operational factors and practical guidance in choosing an entity for a foreign operation.

1. Tax aspects of entity choices for a foreign operation
2. Legal features of entities that tax professionals must grasp
3. U.S. tax advantages and pitfalls with income and losses from different structures
4. Planning the tax analysis for entity selection
5. Preparing Form 8832 Entity Classification Election Form
6. Seeking relief for late elections
7. Reevaluating a previous entity choice

The panel will tackle issues such as:

• Understanding the legal entity alternatives for foreign operations
• Anticipating U.S. tax treatment of income, losses, gains, etc. that will affect the entity decision
• Making fully informed, tax-based decisions/recommendations for the proper entity for a foreign business entity
• Required filings for making entity election and available options in case of late or incorrect elections

Learning Objectives

Upon completing this webinar, you will be able to:

• Discern the tax and operational impacts of various entity choices in setting up a U.S. company’s foreign operation
• Identify tax advantages from structuring “hybrid” entities that receive different treatment for U.S. income tax purposes than in the country where the entities are located
• Recognize the impact of foreign branch or subsidiary entity selection on the tax treatment of repatriated income

• Field of Study: Taxes
• Level of Knowledge: Intermediate
• Advance Preparation: None
• Teaching Method: Seminar/Lecture
• Delivery Method: Group-Internet (via computer)
• Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
• Prerequisite: Three years+ business or public firm experience at mid-level within the organization, supervising other preparers/accountants, preparing complex corporate tax forms and schedules. Specific knowledge of rules governing corporate entity structuring, and federal income tax treatment of business entities. Familiarity with Subpart F rules and concepts of cross-border tax arbitrage and hybrid entities.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).