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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?

GAAP Holding Company Worldwide Effective Tax Rate
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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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