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UK Groups Investing into the US

Duncan Whitecross International Tax Partner Stephen Weston Treasury Tax Partner and Jeff Wehner US Tax Partner Deloitte London discuss the structuring of UK groups' investments in the US
As the world's largest economy the US represents a key market for many UK-based multinational groups. It is estimated that as at the end of 2004 around 30% of UK investment holdings abroad were in the Americas and the majority of these were into the US. The US itself has a relatively high corporate tax rate (35% federal tax rate plus state and local taxes) which itself makes it attractive to structure an investment so as to achieve US tax deductions for interest and other intra-group expenses.
Compared to a number of other jurisdictions ...

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