Читать книгу International Taxation - Adnan Islam - Страница 36

Choosing to operate in a foreign country either as a branch or a corporation has significant tax consequences. For example, determining whether a foreign business operation constitutes a separate corporation for U.S. tax purposes will affect the amount and the timing of available foreign tax credits, the applicability of the pass-through rules of Subpart F, the applicability of other deferral rules of Subchapter C, and a number of other IRC provisions.