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October 15, 2008

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U.S. Tax Issues in Structuring Foreign Operations

As business becomes increasingly international at all levels, from the multinational to the sole proprietor, it is more likely than ever that your business will need to plan its tax strategy on an international basis.  Due to the complex interplay between and among U.S. tax rules, non-U.S. tax rules and double-taxation treaties, properly integrated and cohesive tax planning is essential when business spans international borders. 

This presentation focuses on the U.S. tax issues that those seeking to expand internationally will face.  Whether you have extensive international operations or are just beginning an international expansion, this audio discussion will present the common issues that must be addressed, including the common U.S. federal income tax compliance requirements.

Presentation Objectives:
The objectives of this 60-90 minute audio discussion include providing participants with a conceptual understanding and practical application of the following:

  • Selecting the form of foreign entity, including detailed discussion on the “check-the-box” regulations
  • Dual consolidation losses
  • Overall foreign losses
  • Branch loss recapture
  • Foreign currency transactions
  • Special Cases, including Guardian Industries

Recorded on October 15, 2008, this audio event is available on CD for purchase.

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