International Tax

Outbound Tax Planning for U.S. Multinational Corporations (Portfolio 6380)

  • This Portfolio describes a comprehensive approach to international tax planning for U.S. multinational corporations.


The Bloomberg Tax Portfolio, Outbound Tax Planning for U.S. Multinational Corporations, breaks down international tax planning into six steps. These steps balance the tax and treasury objectives of a U.S. multinational corporation in developing sustainable international tax strategies. Within the description of the steps, the Portfolio describes planning strategies, common issues, and business considerations of various structures. Most importantly, the Portfolio provides a U.S. multinational corporation a framework for approaching international tax planning throughout its lifecycle and the rapidly changing business environment.

Table of Contents

I. Introduction
II. Overview of Outbound Tax Planning for U.S. Multinational Corporations
III. Reduction of U.S. Taxable Income
IV. Foreign Tax Reduction
V. Tax-Efficient Utilization of Foreign Tax Credits
VI. Restructuring Controlled Foreign Corporation Operations and Impact on Planning
Introductory Material
VII. Treasury Functions of the U.S. Multinational Corporation
VIII. Repatriation Overview
IX. Guideposts for Affirmative Planning

T. Timothy Tuerff
Partner, International Tax
Deloitte Tax LLP
Gretchen Sierra
Principal, Washington National Tax - International Tax
Deloitte Tax LLP
Christopher Trump
Deloitte Tax LLP
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