income taxes withholding taxes transfer pricing make sure B u s i n e s s F i n a n c e

income taxes withholding taxes transfer pricing make sure B u s i n e s s F i n a n c e

You  are working as an accountant for a U.S. company, USco, that designs and  manufactures specialized equipment used in various manufacturing  applications. Your company is contemplating expanding its operations  overseas. The CEO has requested that you choose a country that has a tax  treaty with the United States, analyze the impact of global expansion  to your proposed country in several key areas, and prepare a report  detailing your findings. Of particular importance to the CEO are the  following areas for investigation:

What steps should the company take to expand to the proposed expansion country?

What  options are available for how to structure the foreign operation and  what are the tax implications of each structure (branch, subsidiary,  hybrid, etc.)? Consider:

Legal and business factors

Taxation of profits

  1. What structure do you recommend for expansion and why?
  2. Based on the recommended structure, what are the tax implications for USco’s employees? Consider:

U.S. or foreign employees

  1. Implications of living arrangements and time spent in the foreign country
  2. Employment taxes, insurance, and benefits
  3. Options for eliminating double taxation (exclusion vs. credit)
  4. Based on the recommended structure, what are the tax implications for USco as a whole? Consider:

Income taxes

  1. Withholding taxes
  2. Transfer pricing
  3. Make  sure to include a brief historical and economic overview of the country  you chose for your analysis, details on why you feel the proposed  country is a good choice for expansion, and important treaty provisions  relevant to your analysis.
  4. You will want to use the textbook, IRS  website, and other professional literature to determine relevant  information that should be contained in each report. Your completed  report should be well organized, well documented, and clearly focused on  the relevant issues appropriate to the course project. Each report  should conform to the following parameters:
  5. Reference
  • Misey, J., & Schadewald, M. S. (2018). Practical guide to U.S. taxation of international transactions (11th ed.). CCH.