This white paper summarizes basic elements of US international income taxation, with an emphasis on the rules that apply to US persons doing business or investing in foreign countries (i.e., outbound issues).¹

This white paper is intended for general information purposes only. It is not intended as legal, tax, or financial advice. The reader is urged to consult a qualified advisor before making any decisions relating to the matters discussed in this white paper.

^{1 This discussion of US income tax matters is based on existing law as contained in the Internal Revenue Code of 1986, as amended (the “Code”), treasury regulations, administrative rulings, and court decisions as of the date of this memorandum. Future changes to the law may, on either a prospective or retroactive basis, give rise to materially different tax consequence. This white paper does not consider or discuss the impact of various proposals to amend the Code or other tax authorities that could change certain of the matters described in this white paper.}