MyCo is a domestic corporation that your family formed several years ago. To take advantage of foreign market opportunities, the board of MyCo met last month and decided to conduct operations in-country Foreign due to the Foreigns friendly market practices. However, 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. The CFO of MyCo needs to present to the board, among others, the tax ramifications of such a decision and she, therefore, mandated you, as the Head of Foreign Tax Planning Division for guidance. As usual, she wanted your responses in a memo. In that memo, you are required to do only three things:

1. Start by first reflecting on the US system for taxing US multinational corporations, generally.

2. Specifically to MyCo, examine and analyze 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.

3. From a tax-efficient perspective, recommend, with justifications, which option MyCo board should choose.