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