Repatriation

News & Analysis as of

U.S. Treasury Department Takes Action to Slow (But Not Stop) Corporate Inversions: A Summary for Executives

What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more

“Return of Basis” Repatriation Strategy Tested in Tax Court

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more

Kazakhstan’s Law on Legalisation of Property

Legalisation allows release from liability and legitimises the turnover of property. The Law on Amnesty of Kazakhstan Citizens, Repatriates (Oralmans), and Individuals Having Kazakhstan Permanent Residence Permit in...more

If I Had a Hammer – A Creative Method for Repatriating Offshore Corporate Profits

In this era of corporate inversions, there seems to be a lot of mud-slinging going around. Congress and the current Presidential administration would like to label large multi-national corporations as traitors. Somewhere...more

China Business Series: Repatriation of Funds out of China

China imposes controls on the inflow and outflow of foreign exchange. Given the involvement of State Administration of Foreign Exchange and various other governmental agencies in the process, repatriating funds from China can...more

Doing Business in Canada: E-Commerce

E-COMMERCE - Canada has a vibrant Internet community. Because of the great expansion of the Internet in Canadian homes and businesses, Canada and its provinces have, in recent years, regulated Internet activity and...more

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more

Market Entry: United Arab Emirates (Dubai and Abu Dhabi)

The United Arab Emirates (UAE) is a federation of seven Emirates established by a constitution that was promulgated in 1971. Abu Dhabi is the largest of the seven Emirates by geographic size and holds most of the hydrocarbon...more

Rogers Towers: Using Contempt Power to Force Repatriation of Offshore Trust Assets

Offshore asset protection trusts (OAPT) typically have the following characteristics: (1) the trust is governed by the laws of a foreign jurisdiction that does not recognize the judgments or orders of courts of the United...more

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