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