Got a tricky question? Receive an answer from students like you! Try us!

Assignment 3: International Taxation and Foreign Tax Credits - Research Paper Example

Only on StudentShare
Masters
Research Paper
Finance & Accounting
Pages 4 (1004 words)

Summary

Assignment 3: International Taxation and Foreign Tax Credits Name Institution Assignment 3: International Taxation and Foreign Tax Credits Types of organizations that a US-based taxpayer could establish abroad and the various tax impacts that these types of organization may cause An intercontinental tax strategy starts with selecting the type of entity to be considered…

Extract of sample
Assignment 3: International Taxation and Foreign Tax Credits

This will in effect be a form of double taxation (Hines & Rice, 1994). A strategy for a US-Based taxpayer to repatriate earnings from the foreign markets and avoid or mitigate the U.S. tax impact on repatriation Lots of profits that most taxpayers in the U.S attribute to mitigate or avoid taxes should be taxed up to about 35% when they are repatriated. In this context, the client can repatriate his earnings from the business abroad and at the same time avoid taxes using the “Cash Hoards” strategy. The fact that U.S has cash hoards indicate that investment is not being hindered by lack of cash. The tax payer can thus bring money back home by shifting income through transfer pricing, a strategy that will allow him to assign costs to subsidiaries in high-tax nations and profits to tax heavens. The technique can work effectively putting in mind an example set by Google, a company that reduced its taxes by about$3.1 billion in the last three years by shifting most of its earnings attributed abroad eventually to Bermuda. ...
Download paper
Not exactly what you need?

Related Essays

Assignment 3: Tax Credits
Tax credits are neutral and enable the Congress in making certain that specific taxpayers get tax credit as concerns marginal tax rates (Cordes, Ebel, & Gravelle, 2005). This purpose is still relevant for today’s taxpayer because the economy of the country has continued to deteriorate over the years. As such, individual and businesses still need protection from harsh economic times. Fairness of Tax Credits and Their Impacts on Taxpayers According to (Murphy & Higgins, 2011), tax credits provide incentives to taxpayers hence motivating them to actively engage in certain economic activities.…
8 pages (2008 words)
Assignment 3: Tax Reform
Reducing the Tax Bite The tax impact on dividends as well as interest sustained in many ways like owning stocks in an account that is tax free, or by holding stocks that increase in value with time and pay no dividends. Tax Issues it is being argued that the tax structure enforces an extremely high percentage which makes it extremely difficult for corporation in the United States of America to attract investors and raise capital. This in turn has a linchpin affect because no new jobs are created and the entire economical development process is hindered. It is believed that the tax rate needs…
5 pages (1255 words)
Multijurisdictional tax (Inbound taxation and Outbound taxation assignment)
IBM Corporation pays a regular quarterly dividend on the stock. Your previous research concluded that Joe T. is a nonresident alien of the US. 1. Is the income received US source income or foreign source income? What statute did you rely on for your conclusion(s)? Facts Joe T. is a non resident alien of the United States who has invested in 1,000 shares of common stock in IBM Corporation. IBM is registered in Delaware, United States and does most of its business within the United States. The stock owned by Joe T. represents less than 1% of the overall value of IBM Corporation. Interpretation…
12 pages (3012 words)
Multijurisdictional tax final exam (emergency - has limited time!)
Treaty with Country X PERMANENT ESTABLISHMENT 1. For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment" includes especially: a) a place of management; b) a branch; c) an office; d) a factory; e) a workshop; and f) a mine, an oil or gas well, a quarry, or any other place of extraction of natural resources. 3. A building site or construction or installation project, or an installation or drilling rig or ship used for the exploration of…
9 pages (2259 words)
International Taxation - Foreign Persons Trade/ Business and U.S. - Sourced Income
The rules and the tax implication to the foreign investors who invest in US companies will be reviewed with rational judgment throughout this research study. Research Objective The objective of this research is to identify the rules related to investment by foreign persons in the US companies and assess the tax implications for the foreign investors in investing in US companies. Literature Review Foreign investment in the US is an attractive destination for the foreign investors due to the favourable political, social and economic conditions in the country. The foreign investors get the…
4 pages (1004 words)
International Taxation - International Taxation and Foreign Tax Credits
However, in reality the U.S. government ignores this concept of neutrality and imposes taxation on profits earned by U.S. companies in any country outside the border. Thus, U.S. companies who seek to spread businesses overseas are burdened with a combination of tax systems. Such companies are required to pay taxes to the U.S. Government as well as the government of the countries where they are conducting their activities (Henchman, 2011, pp.1-2). This paper contains my proposals as a tax professional to my U.S based client who wants to expand his business into foreign markets. Taxpayer’s…
6 pages (1506 words)
Reforming the U.S. tax code to eliminate tax credits
The goals of the reforms on the taxes is to realize the objectives of the National Commission on Fiscal Responsibility and Reforms, whose major goal is to give the people responsibilities related to the growth of the economy in accordance with the level of affluence (Becerra 45). My Position on Flat Tax Rate Flat tax rates imply that the people pay the same amount of tax regardless of their level of income. When the tax rate is constant, all the taxpayers are to be subjected to the same amount of tax without deductions or exemptions. According to the Americans Bill on the reforms of the tax…
4 pages (1004 words)