Jerald David August presented "U.S. Companies Making Outbound Investments, A Primer" at the NJ Bar Annual Tax Conference

Discussions included choice of entity decisions for U.S. persons engaging in business operations overseas, including the use of hybrid entities; nexus for foreign tax exposure including treaty provisions such as the permanent establishment rule, taxation of foreign source business income.

Other topics included foreign tax credit implications and limitations; anti-foreign tax credit splitting rules; withholding tax implications, transfer pricing issues and moving intangibles overseas. Mr. August also discussed the IC-DISC rules and potential impact of Tax Reform on international business taxation.