Generally, an outbound transaction entails U.S. persons seeking to passively invest or actively engage in business in a foreign tax jurisdiction.
Tax planning for outbound transactions is obviously complex and usually involves:
- Treaty shopping and taking advantage of local jurisdiction tax rules
- Managing foreign tax credits
- Choice of entity
- Formation of foreign entities
- Restructuring operations
- Transferring assets and intangibles
- Debt restructuring
- Planning for repatriation