You are working as an accountant for a U.S. company, USco that designs and manufactures specialized equipment used in various manufacturing applications. Your company is contemplating expanding its operations overseas. The CEO has requested that you choose a country that has a tax treaty with the United States, analyze the impact of global expansion to your proposed country in several key areas, and prepare a report detailing your findings. Of particular importance to the CEO are the following areas for investigation:

1. What structure of the foreign operation do you recommend for expansion and why? [(branch, subsidiary, hybrid, etc.) Consider Legal and Business Factors & the Taxation of profits]
2. Based on the recommended structure, what are the tax implications for UScos employees? Consider:
   1. U.S. or foreign employees
   2. Implications of living arrangements and time spent in the foreign country
   3. Employment Taxes, Insurance, and Benefits
   4. Options for eliminating double taxation (exclusion vs credit)