U.S. Based Parent Corporations with Foreign Branch Operations Need to Take into Account Potential Application of the Overall Foreign and Domestic Loss Rules

U.S. Based Parent Corporations with Foreign Branch Operations Need to Take into Account Potential Application of the Overall Foreign and Domestic Loss Rules

For U.S. taxpayers planning to engage in business operations in foreign countries, especially in start-up type situations,  consideration must be given as to what are the potential tax consequences, including timing differences, for reporting built-in losses and anticipated foreign losses from operations overseas.