Use of holding companies in international tax planning

Article Abstract:

Foreign holding companies, used by either American or foreign multinationals to hold operating subsidiaries in other countries, can provide tax planning advantages in areas such as deferral planning, treaty shopping, blending or mixing companies, and foreign tax credit planning. The disadvantages of holding companies include restructuring problems and the nonapplication of IRC Section 1248 to gain recognized on subsidiary stock sales. Company structuring and inbound treaty shopping are also important considerations. Netherlands holding companies are often used because of that country's tax treatment policies and treaty network.

Holding companies

---

Where in the tax world is Carmen San Diego? How the tax planner can impact international employee assignments

Article Abstract:

International employee assignments requires transnational tax planning and the development of comprehensive employee relocation policies. Multinational companies should address tax reimbursement and moving expense reimbursement policies, expatriate compensation, and other relocation-related policy issues. Tax planning for outbound employees should cover the foreign tax credit, foreign-source income, principal residence or sale, withholding and social security taxes, as well as applicable spousal, housing, income, and foreign earned income exclusions. Inbound tax planning is also discussed.

Multinational Corporations, Employee Relocation Procedures, Planning, Human resource management, Expatriation, Employee relocation

---

Similar abstracts:

• Abstracts: Using a charitable remainder trust in retirement planning. Options available when a family corporation no longer is an operating entity
• Abstracts: Avoiding penalties when there is a disclosure dispute. How aggressive should the tax practitioner be in preparing a client's return?
• Abstracts: The treatment of intangible property rights in international tax planning. "Money" and "property (other than money)": an exploration of "amount realized" under section 1001(b)
• Abstracts: When is a business not a business? Exploiting business opportunities and enhancing economic returns by capitalizing on the income tax exemption of tax-exempt organizations

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.