Tax Planning for U.S. MNCs with EU Holding Companies: Goals, Tools, Barriers
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...
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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
AcknowledgmentsAbbreviationsList of FiguresList of TablesSect. 1Introduction to International Tax Planning for U.S. MNCS17Sect. 2Tax Planning Goals39Sect. 3Tax Planning Tools65Sect. 4Tax Planning Barriers (Subpart F)83Sect. 5Specific Tax Planning Techniques109Sect. 6Future Developments and Summary157References175Table of Double Tax Treaty Law216Table of Treasury Rulings219Table of Cases220Miscellaneous222Index229
