You need to consider the following US IRS reporting and election consequences:
- Controlled foreign corporation rules
- Subpart F income possibilities
- Passive foreign investment company rules.
- Possible Flow Through Election for US tax purposes.
- Subpart F personal holding company rules
- The need to file FBAR forms to report foreign bank accounts
- Transfer Pricing
- Possible Tax on Transferring intangible property and tangible property to a foreign corporation