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Repatriation Tax Avoidance
Repatriation tax avoidance is the legal use of a tax regime within a country in order to repatriate income earned by Subsidiary, foreign subsidiaries to a Holding company, parent corporation while Tax avoidance, avoiding taxes ordinarily owed to the parent's country on the repatriation of foreign income. Prior to the passage of the Tax Cuts and Jobs Act of 2017, multinational firms based in the United States owed the U.S. government taxes on worldwide income. Companies avoided taxes on the repatriation of income earned abroad through a variety of strategies involving the use of mergers and acquisitions. Three main types of strategies emerged and were given names—the "Killer B", "Deadly D", and "Outbound F"—each of which took advantage of a different area of the Internal Revenue Code to conduct tax-exempt Reorganization, corporate reorganizations. The application of repatriation tax avoidance strategies has drawn public scrutiny. Several large corporate acquisitions have inv ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Subsidiary
A subsidiary, subsidiary company, or daughter company is a company (law), company completely or partially owned or controlled by another company, called the parent company or holding company, which has legal and financial control over the subsidiary company. Unlike regional branches or divisions, subsidiaries are considered to be distinct entities from their parent companies; they are required to follow the laws of where they are incorporated, and they maintain their own executive leadership. Two or more subsidiaries primarily controlled by same entity/group are considered to be sister companies of each other. Subsidiaries are a common feature of modern business, and most multinational corporations organize their operations via the creation and purchase of subsidiary companies. Examples of holding companies are Berkshire Hathaway, Jefferies Financial Group, The Walt Disney Company, Warner Bros. Discovery, and Citigroup, which have subsidiaries involved in many different Industry (e ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Killer B Pseudo-reorganization Acquisition Diagram
A killer is someone or something that kills, such as a murderer or a serial killer. Killer may also refer to: Arts, entertainment, and media Fictional characters * Killer, the secondary antagonist of the 1989 animated film ''All Dogs Go to Heaven'' * Killer (''Home and Away''), a character from ''Home and Away'' * Killer Kane, the villain of the 1939 serial film ''Buck Rogers'' Films * ''Killer!'' (1969 film), an alternative title for ''This Man Must Die'' * ''Killer'', a 1972 French crime drama directed by Denys de La Patellière * ''Killer'' (1991 film), a Telugu film starring Akkineni Nagarjuna * ''Killer'' (1994 film) (a.k.a. ''Bulletproof Heart''), a film starring Anthony LaPaglia and Mimi Rogers, and featuring Peter Boyle * ''Killer: A Journal of Murder'' (film), a 1996 film about serial killer Carl Panzram * ''Killer'' (1998 film), a French/Kazakhstani crime drama Games * Killer (game), a parlor game played with cards and candles * Killer (pool), a multi-player ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Dutch Sandwich
Dutch Sandwich is a base erosion and profit shifting (BEPS) corporate tax tool, used mostly by U.S. multinationals to avoid incurring European Union withholding taxes on untaxed profits as they were being moved to non-EU tax havens (such as the Bermuda black hole). These untaxed profits could have originated from within the EU, or from outside the EU, but in most cases were routed to major EU corporate-focused tax havens, such as Ireland and Luxembourg, by the use of other BEPS tools. The Dutch Sandwich was often used with Irish BEPS tools such as the Double Irish, the Single Malt and the Capital Allowances for Intangible Assets ("CAIA") tools. In 2010, Ireland changed its tax-code to enable Irish BEPS tools to avoid such withholding taxes without needing a Dutch Sandwich. Explanation The structure relies on the tax loophole that most EU countries will allow royalty payments be made to other EU countries without incurring withholding taxes. However, the Dutch tax code ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Janssen Pharmaceuticals
Johnson & Johnson Innovative Medicine (formerly Janssen Pharmaceuticals) is a Belgian pharmaceutical company headquartered in Beerse, Belgium, and wholly owned by Johnson & Johnson. It was founded in 1953 by Paul Janssen. In 1961, Janssen Pharmaceuticals was purchased by New Jersey–based American corporation Johnson & Johnson, and became part of Johnson & Johnson Pharmaceutical Research and Development (J&J PRD), later renamed to Janssen Research and Development, LLC (JRD), which conducts research and development activities related to a wide range of human medical disorders, including mental illness, neurological disorders, anesthesia and analgesia, gastrointestinal disorders, fungal infection, HIV/AIDS, allergies and cancer. Janssen and Ortho-McNeil Pharmaceutical have been placed in the Ortho-McNeil-Janssen group within Johnson & Johnson Company. Subsidiaries * Actelion * Cilag AG * Janssen Biotech (formerly ''Centocor'') * Janssen Vaccines (formerly ''Crucell'') * ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
The Wall Street Journal
''The Wall Street Journal'' (''WSJ''), also referred to simply as the ''Journal,'' is an American newspaper based in New York City. The newspaper provides extensive coverage of news, especially business and finance. It operates on a subscription model, requiring readers to pay for access to most of its articles and content. The ''Journal'' is published six days a week by Dow Jones & Company, a division of News Corp. As of 2023, ''The'' ''Wall Street Journal'' is the List of newspapers in the United States, largest newspaper in the United States by print circulation, with 609,650 print subscribers. It has 3.17 million digital subscribers, the second-most in the nation after ''The New York Times''. The newspaper is one of the United States' Newspaper of record, newspapers of record. The first issue of the newspaper was published on July 8, 1889. The Editorial board at The Wall Street Journal, editorial page of the ''Journal'' is typically center-right in its positio ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Big Four Accounting Firms
The Big Four are the four largest professional services networks in the world: Deloitte, Ernst & Young, EY, KPMG, and PwC. They are the four largest global accounting networks as measured by revenue. The four are often grouped because they are comparable in size relative to the rest of the market, both in terms of revenue and workforce; they are considered equal in their ability to provide a wide scope of professional services to their clients; and, among those looking to start a career in professional services, particularly accounting, they are considered equally attractive networks to work in, because of the frequency with which these firms engage with Fortune 500, ''Fortune'' 500 companies. The Big Four all offer audit, assurance services, assurance, taxation, management consulting, Valuation (finance), valuation, market research, actuarial, corporate finance, and legal services to their clients. A significant majority of the audits of Public company, public companies, as w ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Bond (finance)
In finance, a bond is a type of Security (finance), security under which the issuer (debtor) owes the holder (creditor) a debt, and is obliged – depending on the terms – to provide cash flow to the creditor (e.g. repay the principal (i.e. amount borrowed) of the bond at the Maturity (finance), maturity date and interest (called the coupon (bond), coupon) over a specified amount of time.) The timing and the amount of cash flow provided varies, depending on the economic value that is emphasized upon, thus giving rise to different types of bonds. The interest is usually payable at fixed intervals: semiannual, annual, and less often at other periods. Thus, a bond is a form of loan or IOU. Bonds provide the borrower with external funds to finance long-term investments or, in the case of government bonds, to finance current expenditure. Bonds and Share capital, stocks are both Security (finance), securities, but the major difference between the two is that (capital) stockholders h ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Deloitte
Deloitte is a multinational professional services network based in London, United Kingdom. It is the largest professional services network in the world by revenue and number of employees, and is one of the Big Four accounting firms, along with EY, KPMG, and PwC. The Deloitte network is composed of member firms of Deloitte Touche Tohmatsu Limited ( ) a private company limited by guarantee incorporated in England and Wales. The firm was founded by accountant William Welch Deloitte in London, England in 1845 and expanded into the United States in 1890. It merged with Haskins & Sells to form Deloitte Haskins & Sells in 1972 and with Touche Ross in the US to form Deloitte & Touche in 1989. In 1993, the international firm was renamed Deloitte Touche Tohmatsu, later abbreviated to Deloitte. In 2002, Arthur Andersen's practice in the UK as well as several of that firm's practices in Europe and North and South America agreed to merge with Deloitte. Subsequent acquisitions have inc ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Outbound F Pseudo-reorganization Acquisition Diagram
Outbound refers to a direction Direction may refer to: *Body relative direction, for instance left, right, forward, backwards, up, and down ** Anatomical terms of location for those used in anatomy ** List of ship directions *Cardinal direction *Bearing (navigation) Mathemat ... of trains, other transport, or roads that travel away from the city center. It may also refer to: __NOTOC__ Arts, entertainment, and media Music * ''Outbound'' (Béla Fleck and the Flecktones album), 2000 * ''Outbound'' (Christian Bautista album) * ''Outbound'' (Keldian album), an album by symphonic power metal band Keldian * ''Outbound'' (Stuart Hamm album) Other arts, entertainment, and media * ''Outbound'' (film), a Romanian film Brands and enterprises *Outbound Systems, manufacturer of the Outbound Laptop, an early Apple Macintosh compatible laptop computer * Rans S-21 Outbound, an American kit aircraft design See also * Outward Bound (other) {{disambiguation ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Deadly D Pseudo-reorganization Acquisition Diagram
Deadly may refer to: * Deadliness, the ability to cause death Arts and entertainment * ''Deadly'', a 2011 novel by Julie Chibbaro * ''Deadly'', a children's book series by Morris Gleitzman and Paul Jennings * ''Deadly'' (Australian TV series), an Australian children's television cartoon series * ''Deadly'' (film), a 1991 Australian film * ''Deadly'' (franchise), a British wildlife TV documentary series * Deadly Awards, also known as The Deadlys, awards for excellence given to Indigenous Australians for achievement in music, sport, entertainment and community * ''Deadly'' film series, an Indian Kannada-language film series including ** ''Deadly Soma'' (2005) ** ''Deadly-2'' (2010) * ''Karla'' (film), a 2006 American movie originally titled ''Deadly'' Other uses * Alan Dedicoat (born 1954), BBC announcer nicknamed "Deadly" * Deadly, a word in Aboriginal Australian English meaning excellent, similar to "wicked" or "awesome" in English slang See also * Lethal (disambiguation ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Slate (magazine)
''Slate'' is an online magazine that covers current affairs, politics, and culture in the United States. It was created in 1996 by former '' New Republic'' editor Michael Kinsley, initially under the ownership of Microsoft as part of MSN. In 2004, it was purchased by The Washington Post Company (later renamed the Graham Holdings Company), and since 2008 has been managed by The Slate Group, an online publishing entity created by Graham Holdings. ''Slate'' is based in New York City, with an additional office in Washington, D.C. ''Slate'', which is updated throughout the day, covers politics, arts and culture, sports, and news. According to its former editor-in-chief Julia Turner, the magazine is "not fundamentally a breaking news source", but rather aimed at helping readers to "analyze and understand and interpret the world" with witty and entertaining writing. As of mid-2015, it publishes about 1,500 stories per month. A French version, ''slate.fr'', was launched in Februa ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Service
The Internal Revenue Service (IRS) is the revenue service for the Federal government of the United States, United States federal government, which is responsible for collecting Taxation in the United States, U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory tax law. It is an agency of the United States Department of the Treasury, Department of the Treasury and led by the Commissioner of Internal Revenue, who is appointed to a five-year term by the President of the United States. The duties of the IRS include providing tax assistance to taxpayers; pursuing and resolving instances of erroneous or fraudulent tax filings; and overseeing various benefits programs, including the Affordable Care Act. The IRS originates from the Commissioner of Internal Revenue, a federal office created in 1862 to assess the nation's first income tax to fund the American Civil War. The temporary measure funded over a fifth of the Union's war expens ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
