So there you have it.

– Make sure you are not forced into a choice by a foreign law.

– Decide based on business practicalities that you will have a foreign entity.

– Assume “invisible” is better.

– Try to disprove this in favor of “deferral” by financial projections. Figure out if the deferral strategy generates tax savings.

Those tax savings–if used correctly–act like a tax-free working capital loan from Uncle Sam. What is your return on investment for working capital plowed into your business? That’s the upside of the deferral strategy. Compare it against the cost of setting up and running the structure. Cost/benefit balance? How does it look.

You’re done. Good luck