Foreign Corporations
Foreign Corporations:
Corporate law is not the same worldwide. Concepts of entities otherwise known in the United States as a corporation can be quite different in other countries.
The uses of foreign corporations are different with every case. Sometimes, the foreign corporation is used to conduct business in the foreign jurisdiction.
That use, however, has many complex legal issues associated with it, such as:
- Double Taxation
- Income, Gift, and Estate taxation in the foreign jurisdiction.
- Protection for personal liability for the liabilities of the foreign corporation.
- Treaties with the United States concerning operation of the business from a financing, accounting, tax, and legal perspective.
- Capital management in a foreign jurisdiction.
- Source of income rules.
- Controlled foreign corporations
- Subpart F income taxation.
- Obtaining a credit for foreign taxes paid.
- International corporate reorganizations.
- Foreign trade.
If you are considering a foreign corporation, or have issues with a foreign corporation, consult with a competent tax attorney or accountant in forming such an entity or addressing such issues. The legal and tax issues are vast and complex.
