U.S. International Tax Planning

Council for International Tax Education (July 13-15, 2009)

Douglas Stransky  presented “Structuring Foreign Disregarded or Check-the-Box (CTB) Entities” as part of a two and one-half day technical update on the latest U.S. international tax strategies for U.S. multinationals.  He discussed choosing the right vehicle for investing overseas - branch v. corporation v. hybrid entity; understanding the CTB rules for foreign entities – planning for S corporations or LLCs; reporting transactions involving branches and foreign disregarded entities – computing Section 987 gains/losses; translation v. transaction gain (loss) – determining the functional currency for foreign entities under Section 985; and the U.S. tax consequences of dual consolidated losses – new rules for overall U.S. or foreign losses.