The complexity of taxation exceeds all bounds when fastened to a multinational corporation (MNC). In a maze of rules that are always changing, a tax practitioner in the MNC landscape must be extremely well informed and ready to act with sound strategic judgement. To such a practitioner, this planning guide - which covers tax-planning considerations in depth for US companies doing business in the EU - should be of value. Starting from the proposition that holding company regimes are generally favourable in Europe - and poised to become more so as the Societas Europaea (SE) becomes established - Professor Dorfmueller analyzes the design of tax conversion and deferral structures that are advantageous to US multinationals as they pursue the following crucial objectives of tax planning. It covers: satisfying goals, such as minimizing liability, maximizing credits, deducting expenses and utilizing losses; using appropriate tools, such as routing of income and classification of entities; and overcoming barriers, especially those erected by the controlled foreign corporation (CFC) provisions of the US tax law known as "Subpart F".A detailed examination of how these methodologies are best pursued under US federal corporate law is complemented by an equally precise analysis of European company taxation, with specific tax planning techniques spelled out for Germany, France, the Netherlands, Belgium, Austria, Denmark, Ireland, Spain, Luxembourg and Switzerland. The reader should find many valuable suggestions on such specialised techniques as onshore pooling in the UK, gaining access to favourable Argentine taxation via a Spanish holding company, and the potential tax ramifications of EU enlargement.
Tax Planning for U.S. MNCs with EU Holding Companies
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