Selection of a Tax Favored Jurisdiction For US Investment: Analyzing the Protections And the Costs

Christopher S. Armstrong

Each TFJ has its own personality, its own strengths and its own weaknesses — there is no one jurisdiction that will be best for all foreign persons investing in the U.S. in all circumstances.

Assuming that the foreign investor will either be a non-resident alien individual with respect to the U.S. or a foreign corporation controlled · by a small group of non-resident alien individuals (hereinafter referred to as “NRA”), the following preliminary issues might be addressed.