Final Problem - Legal Entity Structure
1. What are potential tax consequences to consider in the below scenarios?
a. The US manufactures product and sells to Russian CFC, who sells to consumers
b. German Service Company provides regional services to all of Europe, some of which are performed in the UK
c. US Parent Co. Transfers Russian CFC to Germany Hold Co. in a tax-free Section 351 contribution
d. US Parent Co. owns only 9% of Russia CFC, (the remainder is held by other US parents) and has subpart F income
e. Germany Op. Co pays a dividend to Germany Hold Co.
2. Compute E&P and tax pools of Germany Hold Co. as of 6/30/xx15 assuming the CFC look-through provisions apply given the facts on the next page. Also compute the current year subpart F inclusion from all entities and tax cost on distribution to US Parent Company.
3. Given the same information as #3, compute E&P and tax pools of Germany Hold Co. as of 6/30/xx15 assuming the CFC look-through provisions do NOT apply given the facts on the next page.
4. What question(s) should be considered in light of the answers above?
Attachment:- Assignment File.rar