Question

In the context of unbundling cash flows from subsidiary to parent, explain how each of the following creates a conduit. What are the tax consequences of each?
a. Imports of components from the parent.
b. Payment to cover overhead expenses of parent managers temporarily assigned to the subsidiary.
c. Payment of royalties for the use of proprietary technology.
d. Subsidiary borrowing of funds of an intermediate or long-term maturity from the parent.
e. Payment of dividends to the parent.


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  • CreatedOctober 13, 2015
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