Choose a multi-national corporation to present information on in the discussion. Please do not discuss a company that someone else in class has already selected. You can find information on the corporation from its website and/or the SEC’s Edgar database. Provide general background information including the name of the corporation, the country in which it is headquartered, some of the countries in which it does business, and the company’s industry. Then, using information gained from the company’s website or Form 10-K (available in the SEC’s Edgar database), discuss a Module 2 tax issue relevant to the company, such as whether the company is required to file consolidated tax returns, any Net Operating Loss of the company, taxation of dividends paid, etc.
Coca Cola.
Definitions, 26 U.S. Code § 1504(a)(4) (n.d.). Retrieved from Thomson Reuters Checkpoint database.
Earnings and profits, 26 CFR § 1.1502-33(f) (n.d.). Retrieved from Thomson Reuters Checkpoint database.
Filing consolidated returns, 26 CFR § 1.150-2-75 (n.d.). Retrieved from Thomson Reuters Checkpoint database.
Special aggregate stock ownership rules, 26 CFR § 1.1502-34 (n.d.). Retrieved from Thomson Reuters Checkpoint database.
Tax Cuts and Jobs Act of 2017, Pub. L. 115-97.
Transfer to corporation controlled by transferor, 26 U.S. Code § 351 (n.d.). Retrieved from Thomson Reuters Checkpoint database.
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