Tax Planning for U.S. MNCs with EU Holding Companies

Tax Planning for U.S. MNCs with EU Holding Companies
Author: Pia Dorfmueller
Publisher:
Total Pages: 250
Release: 2003
Genre: International business enterprises
ISBN:

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Tax planning for U.S. companies doing business in the EU. Analyses the design of tax conversion and deferral structures that are advantageous to U.S. multinationals to reach their goals: minimizing liability, maximizing credits, deducting expenses, and utilizing losses; using tools such as routing of income and classification of entities; and overcoming barriers like the CFC provisions of the U.S. tax law. Examines U.S. federal corporate law and analyses European company taxation, with specific tax planning techniques for Germany, France, the Netherlands, Belgium, Austria, Denmark, Ireland, Spain, Luxembourg, and Switzerland.

Tax Planning with Holding Companies - Repatriation of US Profits from Europe

Tax Planning with Holding Companies - Repatriation of US Profits from Europe
Author: Rolf Eicke
Publisher: Kluwer Law International B.V.
Total Pages: 526
Release: 2009-01-01
Genre: Law
ISBN: 9041127941

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The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.

Tax Planning with Holding Companies - Repatriation of US Profits from Europe

Tax Planning with Holding Companies - Repatriation of US Profits from Europe
Author: Rolf Eicke
Publisher:
Total Pages: 520
Release: 2008
Genre:
ISBN: 9789041135155

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When investments don't live up to their promise, the situation is typically due to several factors. In most cases, the key reasons are a combination of the place of investment, the product, and the selection of detrimental tax planning measures. Often, international tax planning tips the scales regarding the success of a U.S. investment in Europe. This timely book analyzes concepts and structures that can be used as a ""construction kit"" applying combinations of basic tools to meet the challenges of an ever-changing global tax environment. In the wake of globalization, a host of n.

The Effects of Taxation on Multinational Corporations

The Effects of Taxation on Multinational Corporations
Author: Martin Feldstein
Publisher: University of Chicago Press
Total Pages: 338
Release: 2007-12-01
Genre: Business & Economics
ISBN: 0226241874

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The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.

Using Treaties and Holding Companies for Latin American Tax Planning

Using Treaties and Holding Companies for Latin American Tax Planning
Author: Amanda D. Johnson
Publisher: WorldTrade Executive, Inc.
Total Pages: 170
Release: 2005
Genre: Business & Economics
ISBN: 9781893323704

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Collection of articles providing an insight in the current status of tax treaties in Latin American and Caribbean countries, and dealing with holding companies and technical assistance, royalty and service payments.

Corporate Profit Shifting

Corporate Profit Shifting
Author: Dorian L. Peters
Publisher:
Total Pages: 171
Release: 2015
Genre: BUSINESS & ECONOMICS
ISBN: 9781634837750

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Congress and the Obama Administration have expressed interest in addressing multinational corporations' ability to shift profits into low- and no-tax countries with little corresponding change in business operations. Several factors appear to be driving this interest. Economists have estimated that profit shifting results in significant tax revenue losses annually, implying that reducing the practice could help address deficit and debt concerns. Profit shifting and base erosion are also believed to distort the allocation of capital as investment decisions are overly influenced by taxes. Fairness concerns have also been raised. If multinational corporations can avoid or reduce their taxes, other taxpayers (including domestically focused businesses and individuals) may perceive the tax system as unfair. At the same time, policymakers are also concerned that American corporations could be unintentionally harmed if careful consideration is not given to the proper way to reduce profit shifting. This book is intended to assist Congress as it considers what, if any, action to curb profit shifting. This book discusses the methods used for shifting profits only to the extent that it is necessary for interpreting the data or discussing policy options. In addition, this book addresses tax havens; basic concepts and policy issues of U.S. international corporate taxation; and reforms of U.S. international taxation.

Where Does Multinational Investment Go with Territorial Taxation? Evidence from the UK

Where Does Multinational Investment Go with Territorial Taxation? Evidence from the UK
Author: Ms.Li Liu
Publisher: International Monetary Fund
Total Pages: 49
Release: 2018-01-13
Genre: Business & Economics
ISBN: 1484337700

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In 2009, the United Kingdom changed from a worldwide to a territorial tax system, abolishing dividend taxes on foreign repatriation from many low-tax countries. This paper assesses the causal effect of territorial taxation on real investments, using a unique dataset for multinational affiliates in 27 European countries and employing the difference-in-difference approach. It finds that the territorial reform has increased the investment rate of UK multinationals by 15.7 percentage points in low-tax countries. In the absence of any significant investment reduction elsewhere, the findings represent a likely increase in total outbound investment by UK multinationals.

Offshore Profit Shifting and the U. S. Tax Code

Offshore Profit Shifting and the U. S. Tax Code
Author: United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations
Publisher:
Total Pages: 648
Release: 2013
Genre: Corporations, American
ISBN:

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Corporate Loss Utilisation through Aggressive Tax Planning

Corporate Loss Utilisation through Aggressive Tax Planning
Author: OECD
Publisher: OECD Publishing
Total Pages: 92
Release: 2011-08-03
Genre:
ISBN: 9264119221

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After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.

T-434/19 Ioana-Felicia Rosca v. European Commission. The Story. Life is a Story - story.one

T-434/19 Ioana-Felicia Rosca v. European Commission. The Story. Life is a Story - story.one
Author: Ioana-Felicia Rosca
Publisher: BoD – Books on Demand
Total Pages: 70
Release: 2024-09-05
Genre: Fiction
ISBN: 3711568041

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This book is based on a real case law at the European Court of Justice, T-434/19, in which the author was the party and indirectly the representative. She took the European Commission to Court as part of the judicial remedies of a recruitment process for permanent AD7 officials of the European Commission. In her writings before the Court she notes "To conclude that the selection board had unlimited discretionary power which is covered by secrecy and no duty to state reasons, would deprive Art. 270 of the Treaty on the Functioning of the European Union of all meaning". Her action in annulment was admitted by the Court in July 2019 and the procedure lasted until September 2022. This is the story, as lived by the applicant.