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)).
FORBES: Fiscal Cliff Tax Deal Extends Key International Rule
Responding to charges filed by Oracle in U.S. federal court in late March, SAP Chief Executive HenningKagermannHenning Kagermann acknowledged Tuesday that TomorrowNow, a subsidiary of the business software specialist, had "inappropriately" downloaded software patches and support documents from rival Oracle--while expressing dismay that Ellison chose to take his beef to U.S. federal courts.
Responding to charges filed by Oracle (nasdaq: ORCL - news - people ) in U.S. federal court in late March, SAP (nyse: SAP - news - people ) Chief Executive Henning Kagermann acknowledged Tuesday that TomorrowNow, a subsidiary of the business software specialist, had "inappropriately" downloaded software patches and support documents from rival Oracle--while expressing dismay that Ellison chose to take his beef to U.S. federal courts.
Throughout the 1990s and early 2000s, private-sector Chinese entrepreneurs could set up offshore ownership structures in Hong Kong, the U.S. or the Cayman Islands, that through a new Chinese subsidiary would acquire operating business assets in China.
Raytheon, a missiles and radar group, is plugging on with reducing its huge debts by selling off some businesses, though its cashflow is still negative and its civil business-jet subsidiary is suffering.
ECONOMIST: America's defence companies are turning dual-purpose
Stagecoach subsidiary Greater Manchester Buses East bought the business and its assets from First Manchester.
Apple channels much of its business in Europe through a subsidiary in the Republic of Ireland, which has lower corporation tax than Britain.
Companies like the BioFuel Energy and Archer Daniels Midland, well organized as the National Biodiesel Board and subsidiary groups, welcome their government-dictated business.
FORBES: The Federal Government's Biodiesel Mandate Ensures Higher Prices All Around
Is this really a legitimate business transaction involving an Italian manufacturing subsidiary, two Caymans corporations and a licensing entity based in the Shetland Islands, or is it just a clever way to avoid paying U.S. taxes?
FORBES: Tax Case Asks Whether IRS Flip-Flopped On Key Position
BP's North American subsidiary and against traders in its Natural Gas Liquids business.
The authority was set up to encourage and manage this new sector but any future business, such as the Lockheed Martin subsidiary UK Seabed Resources, will have to pay royalties to the authority to be distributed to developing countries.
BBC: UK Seabed Resources joins deep-ocean mineral-mining rush
TV, the biggest firm in the business (owned by Hughes Electronics, itself a subsidiary of General Motors) merged with United States Satellite Broadcasting.
Last year Mitsubishi-Tokyo UFJ, operating through the 100 percent subsidiary Union Bank of California, captured 13 percent of this business, placing it in first place.
AOL's strength in the consumer market (over 14m subscribers, with another 2m from its Compuserve subsidiary) should complement Netcenter's greater appeal to the business market.
Shi reportedly refused the two government proposals and wanted to protect the New York-listed Suntech Power by letting its core subsidiary in Wuxi go bankrupt, according to the 21st Century Business Herald report.
FORBES: China's Government To the Rescue As Solar Crisis Deepens
Qualcomm currently uses the licenses to support the service business of FLO TV Incorporated, a wholly owned subsidiary of Qualcomm, and the sale follows Qualcomm's previously announced plan to evaluate strategic options for the FLO TV business.
ENGADGET: AT&T buys Qualcomm's FLO TV spectrum for a cool $1.9b, promises 4G awesomeness
On Tuesday, the Swiss-based wealth manager announced it intended to publicly float the stock of its mutual fund subsidiary Julius Baer Americas, seeking to concentrate on its core private banking business.
B, a subsidiary of News Corporation, which has grown out of the entrepreneurial Australian media business.
In order to focus on their cellular-phone business, SK Telecom folded their NetsGo internet service provider and Lycos Korea into their subsidiary SK Communications in November 2002.
Doble (now a subsidiary of ESCO Technologies) is probably one of the least publicly recognized companies in the power engineering business, which is surprising given their longevity and global reach.
FORBES: Six Decades in the Utility Business With Doble Engineering: A Seasoned Veteran Looks Back
Thus did the fortunate Mr Hall find his champion, and the First Horizon Home Loan Corporation, a subsidiary of First Tennessee Bank, find itself charged under New York law with unlawful collection and deceptive business practices.
Xu Xin, president of Deer Jet, a subsidiary of the Hainan Airlines Group, told China Daily that he is very optimistic about the Chinese business aviation market due to the increasing number of rich people in China and their willingness to spend more on business jets.
Italy is famous for food as well as luxury: in January Princes, a British subsidiary of Japan's Mitsubishi Corporation, said it would buy 51% of a giant tomato-processing business in southern Italy.
Meanwhile, its grocery products business saw no growth in revenue, in large part because of a drop in sales at its Australian subsidiary George Weston Foods.
应用推荐