Inbound and Outbound Entity Structuring

Our SD Global tax professionals have expensive experience in developing optimal tax structures for both inbound and outbound investments. The structuring of inbound and outbound investments starts with an understanding of the business expansion plans and objectives, and then a careful analysis of the applicable tax rules and rates for the home country and foreign jurisdictions.

The business questions that need to be addressed include:

  • Will NewCo have losses in the early years?
  • Will the income of NewCo be reinvested in the foreign jurisdiction, or will it be repatriated back to the home country?
  • Do longer term plans include a sale of NewCo?

The tax analysis includes a variety of factors, such as:

  • Corporate and individual income tax rates for the home and foreign country
  • Withholding tax rates on dividends, interest and royalties
  • Applicable tax treaty provisions
  • Transfer pricing rules
  • Thin capitalization rules
  • Foreign holding company structures
  • Value added taxes

In connection with the above considerations, one of the most important decisions regarding entity structure is whether to have NewCo taxed as a separate corporate entity or to have it treated as a disregarded entity for US tax purposes by making a "check-the-box" election.

Our SD Global tax professionals have an in-depth understanding of the tax issues facing middle market companies as they seek to expand internationally. We are ready to assist with practical solutions aimed at minimizing the Companys worldwide effective tax rate.

case studies

 
big problem:
A not-for-profit client out of 401(k) compliance.
big thinking:
Allowing more contributions by highly paid employees.
 
big problem:
Hackers attempting a six-figure wire transfer.
big thinking:
Rapid action spearheaded active containment and response.

our thoughts on

Make Europe Great Again
International Tax Update: OECD Releases Latest Edition of Model Tax Convention
Legislation Introduced Preventing Rolling Stock Acquisitions from Chinese Manufacturers
EU Efforts to Stem Abusive Tax Structures

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Map of Pittsburgh Office
Pittsburgh

One PPG Place, Suite 1700
Pittsburgh, PA 15222

contactsd@schneiderdowns.com
p:412.261.3644     f:412.261.4876

Map of Columbus Office
Columbus

65 East State Street, Suite 2000
Columbus, OH 43215

contactsd@schneiderdowns.com
p:614.621.4060     f:614.621.4062