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Branch Profits and Branch Interest Taxes

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A dividend distribution to a foreign parent of a US subsidiary would be taxed as US source income to the foreign parent. When a foreign business operates a branch in the US, the IRS imposes branch tax on the US branch profit in order to put the US branch on equal footing with a US subsidiary […]

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Transfer Pricing

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Taxpayers with affiliates located in lower tax jurisdictions may seek to reduce their income subject to US income tax by using transfer pricing arrangements that artificially shift income away from (or deductions to) the US, in favor of the lower tax jurisdiction. To combat these abuses, the transfer pricing rules give the IRS the power […]

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