Store International Tax Planning for US MNCs with EU Holding Companies: Goals - Tools - Barriers
Tax Planning for US MNCs with EU Holding Companies: Goals - Tools - Barriers

Tax Planning for US MNCs with EU Holding Companies: Goals - Tools - Barriers

By Pia Dorfmueller


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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 judgment. To such a practitioner, this highly informative and expert planning guide, which covers tax planning considerations in depth for U.S. companies doing business in the EU, is of immeasurable value.

Starting from the proposition that holding company regimes are generally favorable 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 U.S. multinationals as they pursue the following crucial objectives of tax planning:

  • 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 U.S. tax law known as ¿Subpart F.¿

    A detailed examination of how these methodologies are best pursued under U.S. federal corporate tax 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 will also find many valuable suggestions on such specialized techniques as onshore pooling in the U.K., gaining access to favorable Argentine taxation via a Spanish holding company, and the potential tax ramifications of EU enlargement.

    A timely book that offers sound theoretical underpinnings as well as practical guidance, Tax Planning for U.S. MNCs with EU Holding Companies more than fulfills the promise of its title. Tax and financial planning professionals will find it unmatched for the depth and clarity of its treatment of this important subject.

  • Publish Date 06/06/2003
    Product Line Kluwer Law International
    ISBN 9789041199225
    SKU 10058584-0001
    Table of Contents
      List of Figures
      List of Tables

      Section 1: Introduction to International Tax Planning for U.S. MNCs
      1. Introduction
      2. Holding Companies as Key International Tax Planning Tools
      3. Basic Concepts of U.S. Federal Income Taxation

      Section 2: Tax Planning Goals
      1. Avoidance and Minimization of Foreign Withholding Taxes
      2. Deduction of Expenses
      3. Immediate Utilization of Losses

      Section 3: Tax Planning Tools
      1. Routing of Income
      2. Conversion of Income
      3. Classification of Entities (Check-the-Box Regulations)

      Section 4: Tax Planning Barriers (Subpart F)
      1. Purpose and Tax Consequences
      2. Requirements
      3. Impacts FTCs
      4. Conclusion

      Section 5: Specific Tax Planning Techniques
      1. Country-by-Country Synopsis
      Austria. Belgium. Denmark. France. Germany. Ireland. Luxembourg. The Netherlands. Spain. Switzerland. Summary Table.
      2. New Luxembourg/U.S. Income Tax Treaty
      3. Double Dip
      4. Achieving Full FTC by Issuing a Hybrid Instrument
      5. Shifting Income to Low-Tax Jurisdictions
      6. Achieving Tax-Exempt Capital Gains
      7. New U.K. Onshore Pooling Provision
      8. Spain as a Gateway to Argentina
      9. EU Enlargement

      Section 6: Future Developments and Summary
      1. The Department of the Treasury Subpart F Study
      2. Harmful Tax Competition
      3. EU Internal Market without Tax Obstacles and EU Company Taxation
      4. European Company (The So-called Societas Europaea)
      5. Summary

      Table of Double Tax Treaty Law
      Table of Treasury Rulings
      Table of Cases