David Noren will be speaking during the session on "Tax Concerns for US Persons Investing or Operating Outside the US (Outbound Investments) – Active Business Operations". The session will cover the following topics:
- Corporation operating directly (branch form)
- Business conducted in a pass-through entity (i.e., an entity treated as a partnership for US tax purposes)
- Corporation operating through a corporate subsidiary (Controlled Foreign Corporation[CFC])
This year’s seminar program led by international tax experts, focuses on specific types of outbound and inbound investment and activities, and their US tax consequences. Each panel will focus upon the issues raised by inbound and outbound investments and describe how the US tax rules address the issues raised. In particular, each panel will focus upon how these rules impact financings, mergers, acquisitions and other commercial activities.