U.S. Inbound Business Tax Planning (Portfolio 6580)

moens-bernard-2015

Bernard Moens

Principal

Pricewaterhousecoopers LLP

Eileen Scott

Managing Director, International Tax Services

PwC US

Joseph Andrus

Head of the Transfer Pricing Unit (retired PwC Partner)

Division of the OECD Center for Tax Policy and Administration

silhan_sidney_2015

Sidney Silhan

Partner

Ernst & Young LLP

At a glance

I. Introduction
II. U.S. Inbound Income Taxation — A Framework
III. State Tax Considerations
IV. Formation of a U.S. Business
V. State Tax Credits and Incentives
VI. Financing U.S. Subsidiary Operations — The Fundamentals
VII. Financing U.S. Subsidiary Operations — Planning
VIII. Ownership of Intangibles
IX. Inbound M& A, Dispositions, and Restructurings

Abstract

The Bloomberg Tax Portfolio, U.S. Inbound Business Tax Planning, addresses topics that are most relevant to foreign-based multinational corporations doing business in the United States. They include a framework of U.S. inbound income taxation, state tax, formation of a U.S. business, financing U.S. operations, ownership of intangible property, and inbound acquisitions and restructurings.

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