My corporation is expanding into Asia and Europe. What type of holding company and entity structure will result in the lowest possible Worldwide Effective Tax Rate for GAAP and tax purposes?
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Tax Professional Answers
Thomas Phalen
A very broad question. Holding companies are under attack currently with several countries passing general anti-avoidance regulations (GAAR) so it is important to provide substance to your holding company. For the Far East and the EU, Singapore (SG) may be a good choice. It has a stable government and treaty network. In many cases a US company will establish a Singapore entity with check-the-box entities in the EU and other countries including IN, CN, AU,etc.
I have seen SG holding companiies (with Pioneer Status) best used as a contract manufacturer dealing with China (CN) 3rd part manufacturers and selling to Check-the-box (CTB) entities. There is substance in the SG company which is a contract manufacturer and no subpart F income on sales to related CTB entities.
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630 weeks ago
I have seen SG holding companiies (with Pioneer Status) best used as a contract manufacturer dealing with China (CN) 3rd part manufacturers and selling to Check-the-box (CTB) entities. There is substance in the SG company which is a contract manufacturer and no subpart F income on sales to related CTB entities.