Page 485 - Large Business IRS Training Guides
P. 485
Real World – Pre-TCJA Paradigm
US Global Parent
(US Rate 35%)
Ltd Risk Dist Co/s Foreign IP HC
Various Countries Bermuda
Tax Rate 30% Tax Rate 0%
Principal Co Ltd Risk Mfg Co
Netherlands Hong Kong
Tax Rate 25% Tax Rate 16.5%
ACTUAL CASE STUDY from: “PRESENT LAW AND BACKGROUND RELATED TO POSSIBLE INCOME
SHIFTING AND TRANSFER PRICING JOINT COMMITTEE ON TAXATION HOUSE COMMITTEE ON WAYS AND
MEANS - July 22, 2010.”
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