QUESTION: I will soon be operating a branch office in the Country of
Switzerland. I currently have an LLC(Delaware) with my home office in
Arlington Virginia. My question is do I need to watch out for any
special US tax traps. I want everything legal from both a US
perspective and a Swiss perspective.

Additionally, if you could recommend a reputable tax
accountant/attorney in the National Capital Region whom has experience
with branch operations in the country of Switzerland I would
appreciate that very much.

REPLY: Pages 132 through 156 of my Controlled Foreign Corporation Tax
Guide provides a brief description of dozens of tax code sections,
most of which represent traps in the form of limitations on deductions
or accelerations of income. (See
http://www.offshorepress.com/cfc-ibc-tax.htm )

When a foreign entity has a branch in the U.S. there is a tax on
distributions of profits that is computed in a way that makes it
effectively equal to the distribution of corporation profits. I'm not
familiar with Swiss tax laws but most of the countries with an income
tax have a branch profits tax.

As for being able to suggest someone as a tax advisor, I can't think
of any offhand but I will post your question to some private email
groups and will forward any replies to you.

Vern