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:

What structure do you recommend for expansion and why? (Branch, Subsidiary or Hybrid company)

1. 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)
2. Based on the recommended structure, what are the tax implications for USco as a whole? Consider:
   1. Income Taxes
   2. Withholding Taxes
   3. Transfer Pricing