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

Making Tax-Based Decisions With Branch Offices, CFCs, Check-the-Box and More

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, December 12, 2017

Recorded event now available

or call 1-800-926-7926

This course will provide corporate tax executives and advisers with practical guidance on short-term and long-term tax issues in selecting an entity for a foreign affiliate, subsidiary, etc. The panel will outline how to navigate the tax consequences inherent in foreign entity selection decisions.


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


Dougherty, Alison
Alison N. Dougherty, J.D., LL.M.


Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and...  |  Read More

Hellkamp, Lori
Lori A. Hellkamp

Jones Day

Ms. Hellkamp practices across a broad range of U.S. federal taxation matters, including corporate and...  |  Read More

Wang, James
James S. Wang

Jones Day

Mr. Wang assists in advising corporations on the tax aspects of complex transactions, including international and...  |  Read More

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