Kollruss, Thomas - In: Journal of Corporate Accounting & Finance 35 (2023) 2, pp. 147-156
This article develops a new strategy for the (tax) optimization of foreign direct investments in the U.S. This strategy … is particularly favorable for natural persons. By using a foreign upstream hybrid partnership, a substantial tax … optimization of the current taxation of profits as well as the taxation of capital gains can be achieved. In addition, current and …