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International Solutions Webinar Series Spotlight: India Sean M. King NC World Trade Association and the US Department o

International Solutions Webinar Series Spotlight: India Sean M. King NC World Trade Association and the US Department of Commerce . Agenda. Legal/Structuring Considerations Tax Planning Considerations India United States Policy Considerations A fluid body of law.

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International Solutions Webinar Series Spotlight: India Sean M. King NC World Trade Association and the US Department o

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  1. International Solutions Webinar Series Spotlight: India Sean M. KingNC World Trade Association and the US Department of Commerce

  2. Agenda • Legal/Structuring Considerations • Tax Planning Considerations • India • United States • Policy Considerations • A fluid body of law

  3. Legal/Structuring Considerations • Foreign direct investment permitted • Few exceptions (atomic energy, gambling) • Choice of entity • US – CTB elections • Use of intermediary holding company?

  4. Tax Planning ConsiderationsIndia • Corporate Tax Rate • 33% for domestic companies • 41% for foreign enterprises • Importance of p/e exposure • VAT • 12.5% • Withholding? • Dividend distribution tax – 16%

  5. Tax Planning ConsiderationsUnited States • Initial investment – sec. 367 • Withholding • Technical services / royalties • Repatriation • Dividend withholding/holdco • Transfer Pricing

  6. Policy Considerations • Recent decisions/regulations demonstrate a fluid body of law • More importantly, underscore macro economic factors • Focus on: • Transfer Pricing • Reorganizations (Star Group case)

  7. Sean M. KingChair, International TaxWilliams MullenRaleigh, NCWashington, DCsking@williamsmullen.com

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