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What is involved in planning for an outbound transaction?

Table of Contents

    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

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