U.S. subsidiaries will typically want to repatriate cash to their foreign parent, which will want a return on its investment in the United States. Although many U.S. subsidiaries will distribute dividends, other repatriation methods are tax-efficient. This program will explain the tax implications of repatriation through dividends, interest, royalties, services, and transfer pricing.

Learning Objectives:

• Identify the tax implications of various repatriation techniques


• Recall the anti-treaty shopping provisions in tax treaties to ensure that your chosen repatriation method is tax-efficient


• Determine how to use transfer pricing principles to your client's advantage