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The purpose of this assignment is to explore and summarize the concepts of multi state or international tax issues. Students will be presented with a fact pattern and will submit a written memo that addresses all of the client’s questions and concerns as presented in the fact pattern. The memo should be at least 2 pages single-spaced, 12 point font, 1” margins. This assignment is due in your Assignments Folder by 11:59 p.m. on the designated due date. Remember to cite references using APA guidelines.
you can use the link to the KPMG Tax Rates Online tool.
INTERNATIONAL TAX – RESEARCH MEMO OPTION 2 USCo, a U.S. corporation, has decided to set up a headquarters subsidiary in Europe. Management has narrowed its location choice to either Spain, or Ireland, or Switzerland. The company has asked you to research some of the income tax implications of setting up a corporation in these three countries. In particular, management wants to know what tax rate will be imposed on corporate income earned in the country and the withholding rates applied to interest, dividends, and royalty payments from the subsidiary to the USCo. To answer the tax rate question, consult KPMG’s Corporate and Indirect Tax Survey 2019, which you can access using the link in the instructions.
To answer the withholding tax questions, consult the treaties between the United States and Spain, Ireland, and Switzerland, which you can access at www.irs.gov (type in “treaties” as your search word). https://home.kpmg/xx/en/home/services/tax/tax-tools-and-resources/tax-rates-online/corporate-tax-rates-table.html