They have identified the US as the biggest growth opportunity and most likely market for an acquirer. Steven has moved permanently to the US to grow the business in the US. Paul lives in the UK and Bruno is based out of the Philippines. Paul and Bruno would also like to move to the US to support the business development.
Prior to relocating to the US, Paul, Steven and Bruno must consider the impact of their US tax residency status on the group structure. Potential impact under the US CFC rules, grantor trust regime and the GILTI provisions may require the group to consider a restructure prior to relocation to ensure they don’t expose themselves to attribution of profits, assets and compliance requirements in the US.