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Practical International Tax Strategies

Proven Solutions to Help You Maximize After-Tax Profits for Your International Operations

Practical International Tax Strategies tells you in clear business language how your colleagues at leading companies are reducing their tax burden in international transactions. Subscribers participate in a dialogue of leading practitioners who consider the best strategies for coping with important new tax rulings, regulations and court decisions, originating both from the US and international sources. To Subscribe>

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Now Available: Global Transfer Pricing Solutions: Fifth Edition

Minimize Your Tax Exposure Worldwide

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Reduce your in-country tax exposure when you build a global business strategy that balances your business goals with sound transfer pricing and tax compliance policies. You'll find insight into the major worldwide transfer pricing regimes with in-depth analysis of proactive transfer pricing management, e-commerce, intellectual property, and much, much more. Learn More

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Current Issue: (for subscribers only)

Practical US/International Tax Strategies Issue Archives
31 Jul 2012

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Download PDF of October 15, 2013 Practical International Tax Strategies
13 Nov 2013

IN THIS ISSUE

China Courts and Tax Authorities Chip Away at Benefits of Offshore Holding Companies

Foreign investments in the PRC are frequently structured through an offshore holding company to reduce red tape and withholding taxes, among others. A recent case, along with recent rulings by the tax authorities, could significantly impinge on holding company advantages. Page 2
 
Ireland's International Tax Strategy: Mostly Good News for MNCs
The Irish government has presented a number of budget measures that could benefit multinational companies. Despite some criticism by other countries, the corporation tax will stay at 12.5 percent. Changes have been proposed to provide more benefits to research and development activities. Page 3
 
Taxpayer Debt Can Qualify for Straddle Treatment
Under temporary regulations issued in September by the IRS, a taxpayer's obligation under a debt instrument can be a position in personal property that is part of a straddle. The temporary regulations will affect taxpayers that issue debt instruments which provide for one or more payments that reference the value of personal property or a position in personal property. Page 4
 
No Reduction of Adjusted Basis of Shares
A recent interpretation by the IRS indicates that in determining the interest expense allocation for foreign tax credit purposes, the taxpayer's adjusted basis in shares of a related foreign corporation should not be reduced by the principal amount of a loan. Page 7

TABLE OF CONTENTS

China--Managing Offshore Holding Companies from China: Recent Case May Suggest Increased Tax Risk. By Charles C. Comey, Matthew Y. Lau, Paul D. McKenzie, Bernie J. Pistillo and Eric N. Roose (Morrison & Foerster LLP), p. 2

Ireland--Ireland Addresses Stateless Income, Confirms Commitment to 12.5 Percent Tax Rate. By Susan Roche, Liam Diamond and Denis Harrington (PricewaterhouseCoopers LLP), p. 3

Norway--The Norwegian Ministry of Finance has Issued a Proposal to Limit the Deduction of Net Interest Expenses Paid to Related Parties. By Frode Talmo (Advokatfirmaet BA-HR DA, Norway), p. 12

OECD--Industry Comments on OECD’s Draft on Transfer Pricing Aspects of Intangibles, p. 14

US--IRS Issues Temporary Regulations on the Application of the Straddle Rules to Debt Instruments, By Peter J. Connors and Stephen C. Lessard (Orrick, Herrington & Sutcliffe LLP), p. 4

Taxpayer Could Not Increase Foreign Tax Credit Due to Interest Expense Allocation. By Edward Tanenbaum and Heather Ripley (Alston & Bird LLP), p. 7



 

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