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

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

Hardcover

$152.00
Choose Expedited Shipping at checkout for guaranteed delivery by Thursday, March 28

Product Details

ISBN-13: 9789041199225
Publisher: Wolters Kluwer Law & Business
Publication date: 06/06/2003
Pages: 236
Product dimensions: 6.14(w) x 9.21(h) x 0.56(d)

Table of Contents

Acknowledgments
Abbreviations
List of Figures
List of Tables

Section 1: Introduction to International Tax Planning for U.S. MNCs
1. Introduction
2. Holding Companies as Key International Tax Planning Tools
3. Basic Concepts of U.S. Federal Income Taxation

Section 2: Tax Planning Goals
1. Avoidance and Minimization of Foreign Withholding Taxes
2. Deduction of Expenses
3. Immediate Utilization of Losses

Section 3: Tax Planning Tools
1. Routing of Income
2. Conversion of Income
3. Classification of Entities (Check-the-Box Regulations)

Section 4: Tax Planning Barriers (Subpart F)
1. Purpose and Tax Consequences
2. Requirements
3. Impacts FTCs
4. Conclusion

Section 5: Specific Tax Planning Techniques
1. Country-by-Country Synopsis
Austria. Belgium. Denmark. France. Germany. Ireland. Luxembourg. The Netherlands. Spain. Switzerland. Summary Table.
2. New Luxembourg/U.S. Income Tax Treaty
3. Double Dip
4. Achieving Full FTC by Issuing a Hybrid Instrument
5. Shifting Income to Low-Tax Jurisdictions
6. Achieving Tax-Exempt Capital Gains
7. New U.K. Onshore Pooling Provision
8. Spain as a Gateway to Argentina
9. EU Enlargement

Section 6: Future Developments and Summary
1. The Department of the Treasury Subpart F Study
2. Harmful Tax Competition
3. EU Internal Market without Tax Obstacles and EU Company Taxation
4. European Company (The So-called Societas Europaea)
5. Summary

References
Table of Double Tax Treaty Law
Table of Treasury Rulings
Table of Cases
Miscellaneous
Index

Customer Reviews

Most Helpful Customer Reviews

See All Customer Reviews