Analysis of International Business & Groups – Consolidated vs. Unitary Affiliation: Planning & Compliance

Please know that ONLY answers found on Bloomberg BNA, RIA Checkpoint, IBFD Tax Research Platform, and CCH will be accepted, as this is not an internet- wide or based analysis.

 1)  Please define and explain what is a Consolidated Group, and how is it treated for US tax purposes? Where would you find it in the US Tax Code (IRC)? What does this have to do with Global Effective Tax Rate measurement?

2)  Please define and explain what is a Unitary Business Group and how is it treated for US tax purposes?  Are these two type of Business Group Models the same?   What make these two distinct for domestic legal purposes and international tax purposes?

3)  Can a Branch Company be an integrate part of a Consolidated or Unitary Business Group?  What is the tax treatment of a Branch company under US tax law?  Explain why it can be said that in certain circumstances Branch Company may be subject to “double taxation” under US tax Law?

4)  Define what a Flow- Through Entity (FTE) is.  Then, define what a Foreign Disregarded Entity (FDE) is?  Are these types of two entities the same?  For US Tax purposes, as related to international tax planning, please discuss how is an FTE & FDE taxed?

5)  Please explain if a Controlled Foreign Company or CFC may be a member of a Consolidated or Unitary Business Group?   Can a CFC be Subsidiary of a US Parent company?  Why are CFCs essential in international tax planning from a US tax purpose?

6)  Please discuss what is concept and general tax treatment of Subpart F Income under US tax law, including what is usually “included” (Full Inclusion) and what is considered excluded income? When can CFCs be considered a type of “hybrid” company?

7)  Using the tax entity architecture and planning principles, please give an example of how would you use a CFC, an FDE or FTE, as Branch or Subsidiary, if you have a company group with a Parent in a high- tax jurisdiction, while at the same time expand your foreign business in an strategic area or region?  What would you do to defer paying tax on taxable income, given that you have a valid and economically substantial reason for keeping active incomemoving between related / affiliated entities outside of the US?  You may explain with illustration…

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