Taxation of Foreign Branches After Tax Reform

Lowell Yoder, David Noren and Susan O’Banion co-authored this bylined article, which notes that while the US tax treatment of a foreign branch owned by a domestic corporation remains fundamentally the same following the 2017 tax reform legislation, “the establishment of a new foreign tax credit basket for branch income, as well as other changes in the legislation, may make it worthwhile to reconsider whether to conduct various foreign operations in corporate or branch form.”