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:

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The choice of structure to be pursued by a U.S. active investor in a foreign country largely depends on the tax treatment of both the host country and the U.S. laws. In many cases, remittances from branches are taxed at a higher rate than dividends from a subsidiary. Therefore, setting up a subsidiary may be the best option for a U.S. active investor in a foreign country from the tax perspective.

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