In November 2014, Michael Karlin presented “Outward Bound –Structuring Considerations for Closely Held Businesses Expanding Abroad,” to STEP Los Angeles. The in-depth presentation explores the critical U.S. tax concepts of class and source of income, entity classification, foreign tax credits, transfer pricing, and anti-deferral rules as they relate to establishing an outbound company.
Outlining the basic tax considerations and losses associated with an outbound start-up, Michael continues to examine the next step in creating a company structure reflective of the taxpayer’s objective, and accompanying tax planning for intellectual property-related income.
