TITLE

WHEN USCORP GOES GLOBAL: TAX RULES AND POLICY CONSIDERATIONS

AUTHOR(S)
Serocki, James
PUB. DATE
January 2007
SOURCE
International Journal of Business Research;2007, Vol. 7 Issue 1, p170
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
This article provides an overview of the tax rules and underlying policy considerations regarding the international tax system for a U.S. corporation (USCORP) commencing foreign operations. A USCORP must deal with many new tax laws and regulations, layered upon domestic operation tax rules, when commencing foreign operations (i.e. "going global"). With the U.S. being a modified worldwide tax system, tax provisions have been enacted in order to mitigate the inherent double taxation disincentives. Certain foreign entity forms have dramatically different tax results including liberal income deferral rules and flow through characteristics which require further tax laws to reign in potential abuses. Tax rules such as foreign tax credit and subpart F must be understood and managed to control the worldwide effective tax rate. A USCORP faces many new tax challenges in establishing a foreign entity and navigating the numerous complex international tax provisions when commencing foreign operations.
ACCESSION #
31515020

 

Related Articles

  • Old Rules and New Realities: Corporate Tax Policy in a Global Setting. Desai, Mihir A.; Hines Jr., James R. // National Tax Journal;Dec2004, Vol. 57 Issue 4, p937 

    This paper reassesses the burden of the current U.S. international tax regime and reconsiders well-known welfare bench-marks used to guide international tax reform. Reinventing corporate tax policy requires that international considerations be placed front and center in the debate on how to tax...

  • POLITICAL WILL. WHITE, SARA // Accountancy;Jun2013, Vol. 150 Issue 1438, p1 

    The author offers opinions on corporation tax law in Great Britain. Hearings of a committee of the House of Lords on tax avoidance by large international business enterprises and on tax avoidance by high technology industries firm Apple Inc. by a committee of the U.S. Senate are cited in support...

  • Cross-Border Business Combinations. Jackman, Patrick; Tretiak, Philip // International Tax Journal;Sep2010, Vol. 36 Issue 5, p5 

    The article focuses on the enactment of new Code Sec. 901(m) by the U.S. Education Jobs and Medicaid Assistance Act of 2010 for dealing with the foreign tax credit (FTC) for foreign income tax in connection with a covered asset acquisition. It discusses the transactions under the covered asset...

  • DESIGNING A U.S. EXEMPTION SYSTEM FOR FOREIGN INCOME WHEN THE TREASURY IS EMPTY. Fleming Jr., J. Clifton; Peroni, Robert J.; Shay, Stephen E. // Florida Tax Review;2012, Vol. 13 Issue 8, p397 

    The article reports the need of a territorial or exemption system in the U.S. under which foreign-source active business income earned by U.S. resident corporations would become substantially free of U.S. income tax. Topics discussed include the need of reform of the U.S. international tax...

  • INCONSISTENT TRANSFER PRICES AND THE LOCATION OF MOBILE CAPITAL. Waegenaere, Anja De; Sansing, Richard // National Tax Journal;Dec2010 Part 2, Vol. 63 Issue 4, p1085 

    We investigate the effects of inconsistent transfer prices on the location and effi ciency of capital investments made by multinational fi rms in a competitive equilibrium. Inconsistent transfer prices create the potential for double taxation. We examine the effects of inconsistent transfer...

  • Discussion of "Who Benefits from Inconsistent Multinational Tax Transfer-Pricing Rules?" PAQUETTE, SUZANNE M. // Contemporary Accounting Research;Spring2006, Vol. 23 Issue 1, p133 

    This article discusses an earlier article in this issue titled "Who Benefits from Inconsistent Multinational Tax Transfer-Pricing Rules," by Anja De Waegenaere, Richard C. Sansing, and Jacco L. Wielhouwer. The article addresses the concerns raised by the increasing adoption of transfer pricing...

  • U.S. taxation of international operations: Trends and new developments. Ruchelman, Stanley C. // International Tax Journal;Winter96, Vol. 22 Issue 1, p1 

    Examines the trends and developments affecting United States taxation of international operations. Expatriation tax; Technical modifications made to the treatment of trusts; Classification of domestic or foreign limited liability companies; International tax simplification bill; Four corporate...

  • The Foreign Earned Income Exclusion: An Update. Oliver, Joseph R. // CPA Journal;Aug99, Vol. 69 Issue 8, p46 

    Discusses foreign earned tax income exclusion in the United States. Ways to achieve foreign residency and the opportunity to exclude income from taxation under the Internal Revenue Code section 911; Discussion on bona fide residence and 330-day presence taxation categories; Income eligible for...

  • How ERTA will benefit expatriate Americans. Searle, Bruce A. // Management Review;Mar82, Vol. 71 Issue 3, p20 

    Explains how the Economic Recovery Tax Act of 198 will benefit expatriate Americans. Tax exemption of foreign income; Requirements to qualify for tax exemptions.

Share

Read the Article

Courtesy of THE LIBRARY OF VIRGINIA

Sorry, but this item is not currently available from your library.

Try another library?
Sign out of this library

Other Topics