The precise shape of the structure to be pursued by a U.S. active investor - branch, subsidiary, etc. - in a foreign country depends largely on the tax treatment of the host country and U.S. laws. In many cases:

Question

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Remittances from branches are often subject to higher tax rates than dividends from a subsidiary. Therefore, a subsidiary may be a more favorable choice for a U.S. active investor in a foreign country. The other options presented in the question may or may not be applicable in certain situations.

The Precise Shape of the Structure to Be Pursued by a U.S