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Vol 23 No 5 May/June 2018

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Tax Planning for US MNCs with EU Holding Companies: Goals, Tools, Barriers

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ISBN13: 9789041199225
ISBN: 9041199225
Published: May 2003
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £89.00

This is a Print On Demand Title.
The publisher will print a copy to fulfill your order. Books can take between 1 to 3 weeks. Looseleaf titles between 1 to 2 weeks.

The complexity of taxation exceeds all bounds when fastened to a multinational corporation (MNC). In a maze of rules that are always changing, a tax practitioner in the MNC landscape must be extremely well informed and ready to act with sound strategic judgement.

To such a practitioner, this planning guide - which covers tax-planning considerations in depth for US companies doing business in the EU - should be of value.;Starting from the proposition that holding company regimes are generally favourable in Europe - and poised to become more so as the Societas Europaea (SE) becomes established - Professor Dorfmueller analyzes the design of tax conversion and deferral structures that are advantageous to US multinationals as they pursue the following crucial objectives of tax planning.

It covers: satisfying goals, such as minimizing liability, maximizing credits, deducting expenses and utilizing losses; using appropriate tools, such as routing of income and classification of entities; and overcoming barriers, especially those erected by the controlled foreign corporation (CFC) provisions of the US tax law known as ""Subpart F"". A detailed examination of how these methodologies are best pursued under US federal corporate law is complemented by an equally precise analysis of European company taxation, with specific tax planning techniques spelled out for Germany, France, the Netherlands, Belgium, Austria, Denmark, Ireland, Spain, Luxembourg and Switzerland.

The reader should find many valuable suggestions on such specialised techniques as onshore pooling in the UK, gaining access to favourable Argentine taxation via a Spanish holding company, and the potential tax ramifications of EU enlargement.

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Section 1 - introduction to international tax planning for US MNCs: introduction
holding companies as key international tax planning tools
basic concepts of US federal income taxation.
Section 2 - tax planning goals: avoidance and minimization of foreign withholding taxes
deduction of expenses
immediate utilization of losses.
Section 3 - tax planning tools: routing of income
conversion of income
classification of entities (check-the-box regulations).
Section 4 - tax planning barriers (subpart F): purpose and tax consequences
impacts FTCs
Section 5 - specific tax planning techniques: country-by-country synopsis - Austria, Belgium, Denmark, France, Germany, Ireland, Luxembourg, The Netherlands, Spain, Switzerland, summary table
new Luxembourg/US income tax treaty
double dip
achieving full FTC by issuing a hybrid instrument
shifting income to low-tax jurisdictions
achieving tax-exempt capital gains
new UK onshore pooling provision
Span as a gateway to Argentina
EU enlargement.
Section 6 - future developments and summary: the department of the treasury subpart F study
harmful tax competition
EU internal market without tax obstacles and EU company taxation
European company (the so called Societas Europaea)