German managers are generally keener to set up a foreign subsidiary than to buy an existing company.
In 1998 Congress enacted an exception for banking and finance income derived by a foreign subsidiary (IRC section 954(h)).
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The elimination of these exceptions is similarly misguided, as these investments also do not have the effect of making foreign subsidiary funds available to the U.S. parent.
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It was believed to be the first time a Dutch court has held a multinational's foreign subsidiary liable for environmental damage and ordered it to pay damages.
Fortunately, exceptions are provided for loans to and stock held in unrelated U.S. corporations, as these investments do not make foreign subsidiary funds available to the U.S. parent company.
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This rule also permits a group to centralize its foreign finance function in a foreign subsidiary, which can receive interest on loans made to related foreign affiliates without U.S. taxation.
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Alternatively, the proposal would tax certain intangible property related income on a current basis at a rate of 15%, whether derived directly by a U.S. corporation or by a foreign subsidiary.
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It provided that dividends, interest, rents and royalties paid by one foreign subsidiary out of its business profits to a related foreign subsidiary are not subject to current U.S. tax (IRC section 954(c)(6)).
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The California pension fund's lawsuit says Wal-Mart's alleged "rampant corruption" at its largest foreign subsidiary exposes the company to "potentially hundreds of millions of dollars of liability" for violating the federal law against foreign corruption.
We strongly believe that the U.S should adopt a territorial tax system which exempts foreign subsidiary earnings from incremental U.S. tax, thereby encouraging repatriation of foreign earnings to the U.S. without a double taxation penalty.
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It took nearly three months to get government approvals in China for investment in the startup, set up as a wholly owned foreign subsidiary, like many of the early venture-backed Chinese startups, in the Cayman Islands.
And bosses can be sent to prison for up to 20 years if their companies fall foul of the FCPA. In theory, they could be jailed because a staff member at a foreign subsidiary bribed an official without their knowledge.
In enacting the exception, Congress explained that Subpart F is intended to apply to income of a foreign subsidiary that is either passive or easily moveable, and the lack of an exception caused the Congress to be concerned that the Subpart F provisions applied to income that is neither passive nor easily moveable.
FORBES: Key Exception for Foreign Banking and Finance Income Extended by Fiscal Cliff Legislation
Shell's local subsidiary is the top foreign oil producer in the Niger Delta, an oil-rich region of mangroves and swamps about the size of Portugal.
First, foreign parents seemed to use their domestic subsidiary to channel innovation into the country.
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In 2006, the agency signed off on a 2003 intracompany transaction that moved foreign rights to its search technology to an Irish subsidiary managed in Bermuda called Google Ireland Holdings.
To do otherwise may set the precedent that by merely incorporating a subsidiary in the U.S., any foreign owned and operated company would be eligible to acquire -- or merge with -- U.S. security-sensitive firms without CFIUS review.
Politicians and union leaders proclaim that the foreign owners may not be dedicated to keep up investment in the subsidiary, and that the take-over threatens national jobs and other economic interests.
FORBES: Can countries benefit from having their domestic firms acquired by foreign companies?
Ryohin Keikaku, a subsidiary of retail giant Seiyu, was prompted to list its shares when foreign investors became interested after the company opened a store in London.
Croix subsidiary is the third such Ocwen-related entity to be domiciled in a foreign tax haven, joining others in Luxembourg and the Cayman Islands.
In the days of advance corporation tax, a British subsidiary paying dividends to a British parent could escape that tax, but not if the parent was foreign.
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