Download or read book Tax Planning for U S MNCs with EU Holding Companies written by Pia Dorfmueller and published by . This book was released on 2003 with total page 250 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Tax Planning with Holding Companies Repatriation of US Profits from Europe written by Rolf Eicke and published by Kluwer Law International B.V.. This book was released on 2009-01-01 with total page 526 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Tax Planning with Holding Companies Repatriation of US Profits from Europe written by Rolf Eicke and published by . This book was released on 2008 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book The Effects of Taxation on Multinational Corporations written by Martin Feldstein and published by University of Chicago Press. This book was released on 2007-12-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book International Corporate Tax Avoidance A Review of the Channels Magnitudes and Blind Spots written by Sebastian Beer and published by International Monetary Fund. This book was released on 2018-07-23 with total page 45 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
Download or read book The The Indirect Side of Direct Investment written by Jack M. Mintz and published by MIT Press. This book was released on 2010-08-06 with total page 203 pages. Available in PDF, EPUB and Kindle. Book excerpt: Drawing on a unique data set (MiDi) on German multinationals provided by the Deutsche Bundesbank in Frankfurt, Mintz and Weichenrieder confirm the prevalence of indirect financing structures for both outbound and inbound German investment. They find evidence of "treaty shopping!' to avoid withholding taxes (using a third country with more favorable tax rates as a conduit through which to route investments) and of "debt shifting." --
Download or read book Offshore Profit Shifting and the U S Tax Code written by United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations and published by . This book was released on 2013 with total page 648 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Where Does Multinational Investment Go with Territorial Taxation Evidence from the UK written by Ms.Li Liu and published by International Monetary Fund. This book was released on 2018-01-13 with total page 49 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Using Treaties and Holding Companies for Latin American Tax Planning written by Amanda D. Johnson and published by WorldTrade Executive, Inc.. This book was released on 2005 with total page 170 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Global Goliaths written by James R. Hines and published by Brookings Institution Press. This book was released on 2021-04-20 with total page 585 pages. Available in PDF, EPUB and Kindle. Book excerpt: How multinationals contribute, or don't, to global prosperity Globalization and multinational corporations have long seemed partners in the enterprise of economic growth: globalization-led prosperity was the goal, and giant corporations spanning the globe would help achieve it. In recent years, however, the notion that all economies, both developed and developing, can prosper from globalization has been called into question by political figures and has fueled a populist backlash around the world against globalization and the corporations that made it possible. In an effort to elevate the sometimes contentious public debate over the conduct and operation of multinational corporations, this edited volume examines key questions about their role, both in their home countries and in the rest of the world where they do business. Is their multinational nature an essential driver of their profits? Do U.S. and European multinationals contribute to home country employment? Do multinational firms exploit foreign workers? How do multinationals influence foreign policy? How will the rise of the digital economy and digital trade in services affect multinationals? In addressing these and similar questions, the book also examines the role that multinational corporations play in the outcomes that policymakers care about most: economic growth, jobs, inequality, and tax fairness.
Download or read book Corporate Loss Utilisation through Aggressive Tax Planning written by OECD and published by OECD Publishing. This book was released on 2011-08-03 with total page 92 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
Download or read book T 434 19 Ioana Felicia Rosca v European Commission The Story Life is a Story story one written by Ioana-Felicia Rosca and published by BoD – Books on Demand. This book was released on 2024-09-05 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Corporate Profit Shifting written by Dorian L. Peters and published by . This book was released on 2015 with total page 171 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book The Intellectual Property Holding Company written by Jeffrey A. Maine and published by Cambridge University Press. This book was released on 2017-12-07 with total page 311 pages. Available in PDF, EPUB and Kindle. Book excerpt: Many companies that have become household names have avoided billions in taxes by 'parking' their valuable intellectual property (IP) assets in holding companies located in tax-favored jurisdictions. In the United States, for example, many domestic companies have moved their IP to tax-favored states such as Delaware or Nevada, while multinational companies have done the same by setting up foreign subsidiaries in Ireland, Singapore, Switzerland, and the Netherlands. In this illuminating work, tax scholar Jeffrey A. Maine teams up with IP expert Xuan-Thao Nguyen to explain how the use of these IP holding companies has become economically unjustified and socially unacceptable, and how numerous calls for change have been made. This book should be read by anyone interested in how corporations - including Gore-Tex, Victoria's Secret, Sherwin-Williams, Toys-R-Us, Apple, Microsoft, and Uber - have avoided tax liability with IP holding companies and how different constituencies are working to stop them.
Download or read book Tax Avoidance Activities of U S Multinational Corporations written by Sonja Lynne Olhoft and published by . This book was released on 1999 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Intellectual Property Holding Company written by Jeffrey A. Maine and published by Cambridge University Press. This book was released on 2017-12-07 with total page 311 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book investigates how some corporations have avoided tax liability with intellectual property holding companies, and how different constituencies are working to stop them.