Page 263 - International Taxation IRS Training Guides

How
Do Taxpayers Achieve Global Tax

Planning Objectives? (Cont’d)

 Manage tax risks within global
tax strategy

planning that is integrated into the business
• Strategic
strategy

tax and treasury risks
• Minimization of

• Shift
tax risk to lower tax jurisdictions

risk may come from a variety of sources including
• Tax
business
model, transaction flows, tax law changes, tax
planning,
execution and maintenance of transactions,
people,
etc.

and related income to lower tax
• Shifting intangible property
while avoiding 367(d) exposure
jurisdictions,

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