This intensive law course focuses on the design, implementation, and legal analysis of tax-efficient structures for U.S. business operations, particularly for multinational enterprises and foreign investors. It prepares legal and corporate professionals to advise on inbound structures that minimize U.S. tax liability while maintaining compliance with the Internal Revenue Code, anti-deferral regimes, transfer pricing, and treaty networks.
Participants will engage in a step-by-step, hands-on examination of choice-of-entity decisions, holding company arrangements, tax treaty planning, hybrid structures, debt vs. equity financing, and IP planning. The course combines real-life structuring scenarios, transaction simulations, IRS exposure mitigation exercises, and drafting of legal memoranda and tax strategy reports.
Course Objectives
By the end of this course, participants will be able to:
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Evaluate U.S. entity options for inbound operations and their tax consequences.
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Structure U.S. subsidiaries, branches, and flow-through vehicles tax-efficiently.
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Apply tax treaty benefits and avoid exposure to U.S. anti-abuse rules.
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Design intercompany arrangements (IP, services, debt) to manage effective tax rates.
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Understand the impact of GILTI, BEAT, FDII, and subpart F on foreign-parented groups.
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Navigate state-level tax planning considerations and apportionment methodologies.
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Prepare advisory memoranda supporting proposed cross-border business structures.
