U.S. Tax System Favors Foreign Ownership
The U.S. corporate tax system is one of the most burdensome in the world, creating a substantial economic benefit for foreign ownership—rather than U.S. ownership—of a multinational business. U.S....
View ArticleSelling Foreign Subsidiaries Without Tax Cost
Gain on the sale of stock in a foreign subsidiary generally is subject to U.S. taxation. This is the case whether the stock is sold by a U.S. parent or by an intermediate foreign holding company....
View ArticleClik here to view.
Saving Taxes Through Cost Sharing Intangible Property With Foreign Subsidiaries
Globe (Photo credit: Wikipedia) Cost sharing arrangements (CSAs) permit all foreign profits derived from exploiting developed intellectual property (IP) to be earned by foreign subsidiaries. Such...
View ArticlePlanning for Intellectual Property Income — How “Patent Box” Regimes Can Help...
If your company has valuable intellectual property (IP), you should consider taking advantage of a “patent box” regime as a strategy for reducing global tax costs. What is a “Patent Box” regime? A...
View ArticleStaying Competitive — Incorporating Beneficial Foreign Intangible Property...
To stay competitive, many multinational companies are looking at restructuring as a means of lowering taxes paid on income derived from intangible property (IP). Discussed here are some of the key...
View ArticleFiscal Cliff Tax Deal Extends Key International Rule
The tax deal struck over the holidays (The American Taxpayer Relief Act of 2012 (H.R. 8)) temporarily extends a key international tax rule averting the inappropriate U.S. taxation of business earnings...
View ArticleClik here to view.
S Corporations Should Consider Incorporating Foreign Branch Operations in...
taxes (Photo credit: 401(K) 2013) As I pointed out in a blog in early 2012, there are 4.5 million S corporations in the U.S. (S Corporation Association). These businesses are operated in pass-through...
View ArticleClik here to view.
Key Exception for Foreign Banking and Finance Income Extended by Fiscal Cliff...
The tax deal struck over the holidays (The American Taxpayer Relief Act of 2012 (H.R. 8)) temporarily extends a key international tax rule averting the inappropriate U.S. taxation of business earnings...
View ArticleClik here to view.
Corporations Can Prepay Royalties To Access Foreign Cash
Seal of the United States Internal Revenue Service. The design is the same as the Treasury seal with an IRS inscription. (Photo credit: Wikipedia) Foreign subsidiaries of U.S. multinationals generally...
View ArticleSenate Proposal Would Hurt Corporate Investment In U.S.
A harsh rule in the Internal Revenue Code taxes foreign subsidiaries’ profits when funds are loaned to a U.S. company or invested in U.S. stock. These are considered “investments in U.S. property.”...
View Article
