“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, Cod
e § 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:
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Foreign Tax Credits Management
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Entity Structuring
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Foreign Loss Planning
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Maintaining U.S. Deferral
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Repatriation of Earnings
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