What is involved in planning for an outbound transaction?

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What is involved in planning for an outbound transaction?

What is involved in planning for an outbound transaction?

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