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Chapter 18 International Managerial Finance

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Euromarket<br />

The international financial<br />

market that provides for<br />

borrowing and lending<br />

currencies outside their<br />

country of origin.<br />

grossed-up income is calculated. Finally, the related taxes paid in the foreign<br />

country are applied as a credit against the additional U.S. tax liability:<br />

Additional MNC income $100,000<br />

U.S. tax liability at 34%<br />

Total foreign taxes paid<br />

to be used as a credit<br />

$ 34,000<br />

($35,000$6,500) 241,500 41,500<br />

U.S. taxes due<br />

0<br />

Net funds available to the parent MNC<br />

$ 58,500<br />

Because the U.S. tax liability is less than the total taxes paid to the foreign<br />

government, no additional U.S. taxes are due on the income from the foreign subsidiary.<br />

In our example, if tax credits had not been allowed, then “double taxation”<br />

by the two authorities, as shown in what follows, would have resulted in a<br />

substantial drop in the overall net funds available to the parent MNC:<br />

Subsidiary income before local taxes $100,000<br />

Foreign income tax at 35%<br />

235,000<br />

Dividend available to be declared<br />

Foreign dividend withholding tax<br />

$ 65,000<br />

at 10%<br />

26,500<br />

MNC’s receipt of dividends $ 58,500<br />

U.S. tax liability at 34%<br />

219,890<br />

Net funds available to the parent MNC $ 38,610<br />

■<br />

The preceding example clearly demonstrates that the existence of bilateral<br />

tax treaties and the subsequent application of tax credits can significantly<br />

enhance the overall net funds available to MNCs from their worldwide earnings.<br />

Consequently, in an increasingly complex and competitive international financial<br />

environment, international taxation is one of the variables that multinational<br />

corporations should fully utilize to their advantage.<br />

The In Practice box on page 798 discusses the ethical issues of gift-giving and<br />

bribery when doing business in foreign countries, which some consider a form of<br />

additional “taxation.”<br />

Financial Markets<br />

CHAPTER <strong>18</strong> <strong>International</strong> <strong>Managerial</strong> <strong>Finance</strong> 797<br />

During the last two decades the Euromarket—which provides for borrowing and<br />

lending currencies outside their country of origin—has grown rapidly. The<br />

Euromarket provides multinational companies with an “external” opportunity to<br />

borrow or lend funds, with the additional feature of less government regulation.<br />

Growth of the Euromarket<br />

The Euromarket has grown large for several reasons. First, beginning in the early<br />

1960s, the Russians wanted to maintain their dollar earnings outside the legal<br />

jurisdiction of the United States, mainly because of the Cold War. Second, the

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