Sourcing Equity Tax Management Essay

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Sourcing equity / Tax management Contrasting between global tax systems

National taxing has been proven to affect economic decisions made by MNEs. Typically, the settlement of taxation will take two different approaches, which are the worldwide approach and the territorial approach. The first approach will levy taxes based upon the income earned by firms that are controlled in the host country. Therefore, an investor earning income internationally would find his/her income taxed by the local tax authorities. For example, a country such as the United States will tax the income earned based upon firms that are located in the U.S. whether the income is received by firms based in the United States, domestically sourced, and/or foreign sourced (Moffett, Stonehill & Eitemen, 2012). However, an issue that arises is that the taxation does not take into consideration the foreign companies that are based in the United States.

Therefore, the territorial approach will be taken into consideration rather than the worldwide approach. This approach will take the income of firms that are within the legal jurisdiction of the host environment, rather than the country of which the firm is incorporated (Razin & Slemrod, 2010). Although efficient for such a situation, much like the worldwide approach, there are major gaps in coverage if residential firms earn income outside of the country. Only if they are not taxed...

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Therefore, both tax approaches are necessary if the full coverage of income will have to take effect.
Foreign income is taxed based on local policies in the overseas nation where income is raised. Therefore, the country of origin of an MNC endeavors to avoid double taxes on the foreign income through exempting income from country of origin taxation or tax credit on taxes paid for foreign income. Most often, countries are illustrated as having a territorial or a worldwide framework with regards to foreign income of the resident corporations. Based on a global approach, nations tax resident companies on all their incomes whether accrued from overseas or domestic activities. From a territorial framework, countries tax resident companies exclusively on income derived from domestic activities (Razin & Slemrod, 2010). In this case, the income derived from overseas subsidiaries is not taxed in the residence jurisdiction of the parent company regardless of being repatriated. Global jurisdiction of taxing provides tax credits for overseas income earners. On the other hand, territorial nations offering an exception from overseas sources of dividends do not provide foreign tax credits on such incomes.

2. Differences in corporate tax structures found across the globe

The major difference between taxable income and economic income…

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They also attract investors as they will provide a deep and liquid market, allows higher investment returns, and are a form of portfolio diversification. Therefore, an investor will profit from the international debt markets as the credit rankings of most of the borrowers are very well, and the borrowers are willing and able to pay a percentage extra for repayment (Sangiuolo & Seidman, 2008). The international debt market consists of unregulated money and capital markets although the dominant currency is the United States dollar. However, the debt securities denominated in euros have grown as the predictability, liquidity and volatility of the euro consolidates. The major forms of Eurocurrency facilities discussed are short-term bank advances (similar to term loans or fully drawn advances) and standby arrangements (source of 'back-up' fund to meet short-term cash shortfalls). They also include medium- to long-term Eurocurrency loans. International debt markets are attractive to both borrows and investors as they can benefit each member in the end. Since major Eurocurrency facilities are attractive because of the lower cost of borrowing, creating a natural hedge and the size of Eurocurrency markets (Razin & Slemrod, 2010).

4. Distinguishing the characteristics of debt instruments

The international debt market uses debt instruments to regulate borrower's repayment plans and investor's investment plans. A debt instrument is a paper or electronically signed obligation that allows the issuing party to raise funds by promising to repay the lender in accordance with the terms of a contract. The borrower will be set up on a plan in order to repay any money used whether it is a short-term or long-term. Typical debt instruments would include the following: notes, bonds, certificates, mortgages, leasing, or other agreements between a


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