Discussion 1
"Corporate Formation and Liquidation" Please respond to the following:
- You have been hired by a U.S. corporation that wants to form a foreign corporation through the transfer of property. Propose a strategy for the client to transfer property into the foreign corporation that will help the client to avoid or mitigate taxes.
- Your client is a U.S. corporation that wants to liquidate a foreign subsidiary. Propose a strategy for your client that will help the client to avoid or mitigate the tax impact of the liquidation.
Discussion 2
"Export Risk" Please respond to the following:
- Assess the risks of incurring foreign tax in exporting goods from the U.S. Based on your assessment, propose a strategy to minimize or eliminate the foreign tax risk.
- International trade is important for the U.S. There is a lot of discussion regarding countries who may be subsidizing their currency to create a trade imbalance with the U.S., resulting in lost tax revenue. Propose a strategy that the U.S. could deploy to eliminate or offset these subsidies. Support your strategy with examples.