GILTI, Subpart F & BEATAnswered

Foreign-corp branch vs US C-corp — which second-level tax is worse?

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viktor_3c47new member
May 27, 2026 1,450 views 1 answer
branch-profits-taxc-corporationentity-structurewithholding

I'm deciding how to structure my US operations: run them directly through my foreign corporation as a branch, or set up a US C-corporation owned by my foreign parent. I understand the first level of tax is similar, but people say the second-level tax is what really differs. Which path has the worse second-level tax?

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