Outbound Transaction Structuring

“Outbound” refers to U.S. persons with non-U.S. income and/or non-U.S. activities.  A typical outbound circumstance exists where a U.S. headquartered corporation has income and/or activities in other countries. 

Typical cross-border tax issues related to outbound transactions can include: foreign withholding taxes, transfer pricing, foreign tax credits and foreign tax credit limitations, subpart F income, GILTI, Code § 956 inclusions (a.k.a. investments in U.S. property), income tax treaties, etc.

We can assist you with your dealings and investments in foreign markets. Cross-border tax planning strategies focus on relevant business and tax issues, including:
  • Foreign Tax Credits Management
  • Entity Structuring
  • Foreign Loss Planning
  • Maintaining U.S. Deferral
  • Repatriation of Earnings

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Contact Info

  P.O. Box 1278
Columbus, Texas 78934

 +1 (346) 231-1195

 +1 (346) 231-1194

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