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

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


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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

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

Table of Double Tax Treaty Law
Table of Treasury Rulings
Table of Cases

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