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Tax-Efficient Repatriation Methods for Foreign-Owned U.S. Subsidiaries

TAX-EFFICIENT REPATRIATION METHODS FOR FOREIGN-OWNED U.S. SUBSIDIARIES

Cost $12.50
Presentation Length 1.0 hour

Recorded DateJanuary 5, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

U.S. subsidiaries will typically want to repatriate cash to their foreign parent, which will want a return on its investment in the United States. Although many U.S. subsidiaries will distribute dividends, other repatriation methods are tax-efficient. This program will explain the tax implications of repatriation through dividends, interest, royalties, services, and transfer pricing.

Learning Objectives:


  • Identify the tax implications of various repatriation techniques

  • Recall the anti-treaty shopping provisions in tax treaties to ensure that your chosen repatriation method is tax-efficient

  • Determine how to use transfer pricing principles to your client's advantage

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Linkedin

Robert Misey, J.D., LL.M.

Reinhart Boerner Van Deuren s.c.
Chair of the International Department
rmisey@reinhartlaw.com
(312) 207-5456

Reinhartboernervan

Robert Misey leads the International Department for the law firm of Reinhart Boerner Van Deuren and is a former trial attorney for the IRS Chief Counsel (International) in Washington, DC. Robert is Chair of the International Tax Committee for the ABA and a member of the bar in California, Wisconsin, and the District of Columbia. He is also the author of the book, A Practical Guide to U.S. Taxation of International Transactions and Federal Taxation: Practice and Procedure.

About Our Presenter

Reinhartboernervan
At Reinhart Boerner Van Deuren, we know that every trusted relationship begins with understanding. That is why each of our committed attorneys takes the time to listen critically, learn the unique attributes of each client’s business, and work together to build a foundation for success that goes beyond providing legal services. While doing so, we draw upon an exceptionally broad base of experienced attorneys and deep knowledge of the industries and sectors we serve. This blend of active understanding grounded by informed perspective equips our attorneys to deliver uniquely creative, yet efficient, legal counsel.