Facts of the Case:

• MyCo is a domestic corporation that your family formed several years ago.
• The board of MyCo met last month and decided to conduct operations in country Foreign due to the Foreign's friendly market practices.
• MyCo does not have the option of forming a hybrid entity or a reverse hybrid entity in country Foreign.
• The board of MyCo will be meeting next week to further the conversation and ratify the move.

Please explain the U.S. tax advantages that the board of MyCo should consider in deciding whether to form a branch or a corporation in country Foreign.