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
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.
Outline
- Tax aspects of entity choices for a foreign operation
- Legal features of entities that tax professionals must grasp
- U.S. tax advantages and pitfalls with income and losses from different structures
- Planning the tax analysis for entity selection
- Preparing Form 8832 Entity Classification Election Form
- Seeking relief for late elections
- Reevaluating a previous entity choice
Benefits
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
Faculty
Alison N. Dougherty, J.D., LL.M.
Director
Aronson
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and... | Read More
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She specializes in international tax compliance, planning and structuring as a subject matter leader of her firm's international tax practice. Her responsibilities include U.S. Federal and multi-state tax compliance for C corporations, S corporations, partnerships and individuals. She also provides transactional tax planning and structuring services.
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Lori A. Hellkamp
Partner
Jones Day
Ms. Hellkamp practices across a broad range of U.S. federal taxation matters, including corporate and... | Read More
Ms. Hellkamp practices across a broad range of U.S. federal taxation matters, including corporate and international taxation and M&A. Her practice has a particular emphasis on international tax planning, compliance, and tax-efficient structures for cross-border transactions and restructurings. She counsels corporations facing a variety of federal and multijurisdictional tax issues, both internally and before the Internal Revenue Service. She has helped clients obtain favorable private letter rulings; seek competent authority assistance; enter into advance pricing agreements; resolve disputes at Appeals; and navigate complex tax treaty, transfer pricing, FIRPTA, and FATCA issues.
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James S. Wang
Jones Day
Mr. Wang assists in advising corporations on the tax aspects of complex transactions, including international and... | Read More
Mr. Wang assists in advising corporations on the tax aspects of complex transactions, including international and domestic mergers, acquisitions, and spin-offs. He also assists in counseling corporations facing a variety of tax issues, both internally and before the Internal Revenue Service. In each of these areas, he has worked to draft opinion letters for complex tax positions and assisted clients in navigating the IRS's private letter ruling process. Finally, he assists clients in responding to proposed tax regulations through the submission of formal comments and in conferences with the IRS.
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