Non-US Business Entity Selection - How U.S. and Global Taxation Regimes Impact the Decision
Making Critical Tax-Based Choices Regarding Branch Offices, CFCs, Disregarded Entities, Joint Ventures, and Check-the-Box
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax executives and advisors guidance on the full range of short-term and long-term tax issues that arise in selecting the entity type to use for a new foreign operation and pitfalls to avoid if seeking to change the entity type after formation. The panel will outline how to navigate the tax consequences inherent in foreign entity selection decisions.
- 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
- Reevaluating a previous entity choice
The panel will tackle issues such as:
- Understanding the legal forms of entity alternatives for foreign operations.
- Anticipating U.S. tax treatment of income, losses, gains, etc. that will affect the entity decision.
- Understanding U.S. elections available for foreign entities and the impact on U.S. (and, sometimes, foreign) taxation
- Making fully informed, tax-based decisions/recommendations for the proper entity for a foreign business entity.
International Tax Partner
Plante & Moran
Mr. Jonckheere has more than 30 years of corporate and accounting firm experience and works with clients that are... | Read More
Mr. Jonckheere has more than 30 years of corporate and accounting firm experience and works with clients that are expanding internationally with tax matters such as transfer pricing, structuring and foreign tax credit planning. He is a frequent panelist on international tax topics and a founding member of the firm’s National Tax Office.Close
Douglas W. Nakajima, J.D., LL.M
Director – Tax & Business
Mr. Nakajima is National Co-Leader of Marcum’s International Tax Services Group and a member of the Firm’s... | Read More
Mr. Nakajima is National Co-Leader of Marcum’s International Tax Services Group and a member of the Firm’s Tax & Business Services division. He has over 30 years of experience advising U.S. and foreign clients on the tax treatment of domestic and cross-border acquisitions, dispositions and reorganizations, transfer pricing and inbound and outbound business expansion strategies. Prior to joining Smart Devine, he was a Tax Principal with an international accounting firm, Managing Director of Tax for a regional accounting firm and Tax Manager for a Big 4 accounting firm. Mr. Nakajima is a frequent speaker to tax professional associations.Close