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Factoring Receivables: Tax Considerations of Investing Accumulated Foreign Earnings

Article Abstract:

Careful planning can result in redistribution of funds among foreign subsidiaries without tax problems. If proposed legislation changes the position regarding United States factored receivables, methods will still succeed in keeping taxation low. The study discusses the following issues: Section 956 of the Internal Revenue Code, factoring, factoring structures, constructive dividends, United States withholding tax, Subpart F income, United States losses, and proposed legal changes. New methods will need to be devised to invest accumulated earnings of foreign subsidiaries. It is difficult to avoid causing additional taxation since the Code has curbed use of all but the short term loan to United States parent device. Loans for over one year are considered as constructive dividends to the United States parent. The analysis contends that the proposed foreign sales corporation legislation is not even close to ratification.

Author: Leake, J.T., Smith, R.S.
Publisher: Tax Executives Institute, Inc.
Publication Name: Tax Executive
Subject: Business, general
ISSN: 0040-0025
Year: 1984
Foreign investments, Taxation

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Data protection: federal privacy legislation update

Article Abstract:

Canada's Personal Information Protection and Electronic Documents Act is discussed. Use of personal information, even with consent, is restricted - even information collected before the law went into effect.

Author: McNaughton, Elizabeth, Tseng, Alice
Publisher: WorldTrade Executives, Inc.
Publication Name: North American Free Trade & Investment Report
Subject: Business, general
ISSN:
Year: 2001
Canada, Laws, regulations and rules, Privacy, Marketing

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