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When investments don’t live up to their promise, the situation is typically
due to several factors. In most cases, the key reasons are a combination of
the place of investment, the product, and the selection of detrimental tax
planning measures. Often, international tax planning tips the scales regarding
the success of a U.S. investment in Europe.
This timely book analyzes concepts and structures that can be used as a
“construction kit,” applying combinations of basic tools to meet the
challenges of an ever-changing global tax environment. In the wake of
globalization, a host of new tax planning opportunities is available to
Techniques designed to legally reduce the relevant tax burden have
simultaneously become more sophisticated and easier. Consequently this work
analyzes concepts, risks, limits of tax planning, and introduces a model that
allows tax professionals to structure and continuously re-evaluate their tax
planning. Instead of relocating entire companies to other countries, firms can
reduce their tax liability using the techniques and measures of tax planning
described in the model.
The overall goal of the work is to analyze the problem of repatriating U.S.
profits from Europe under an integrated and holistic approach, going far
beyond the routing of income via different companies. Instead, the approach
includes an analysis of the interdependencies between international tax
competition, holding company regimes, and tax planning concepts in order to
establish a basis for tax planning measures regardless of the fast changing
legal environment for holding companies in the different countries.
Contents. Preface. Acknowledgements. List of Figures and Tables. List of
Abbreviations 1. Goals of Research 2. Tax Planning with Holding
Companies 3 Repatriation Strategies 4. U.S. Direct Investment
Abroad and U.S. Profits in Europe 5. Tax Havens 6. Tax
Competition and Tax Harmonization 7. Holding Locations – Side-by-Side
8. Implications of the U.S. law 9. Structures 10. Executive
Summary. Table of European Court of Justice Cases. Bibliography. Index