Cross-Border Tax & FX Navigator
An interactive guide for modeling the U.S. tax implications of financing, repatriation, and foreign exchange for multinational enterprises.
Funding Simulator: Debt vs. Equity
How should a foreign parent fund its U.S. subsidiary? This tool models the U.S. tax trade-offs between a capital contribution (equity) and an intercompany loan (debt). See how interest deductibility, limited by §163(j), compares to the cost of withholding tax on interest payments.
Scenario Inputs
Assumes a 21% U.S. corporate tax rate. Adjust inputs to model your specific scenario.
Net Annual Tax Impact
Repatriation Simulator: Dividends vs. Royalties
Once the U.S. subsidiary is profitable, how can cash be repatriated efficiently? This tool compares paying a non-deductible dividend with paying a deductible royalty. It models the total U.S. tax leakage (corporate tax + withholding tax) to show the net cash received by the foreign parent.
Scenario Inputs
Net Cash Received by Foreign Parent
§988 FX Impact Calculator
Calculate the U.S. tax impact of foreign exchange fluctuations on an open transaction. Enter the details of a non-functional currency payable or receivable to see how currency movements create ordinary, U.S.-source income or loss under IRC Section 988.
Transaction Details
Calculated §988 Impact
This amount is treated as ordinary, U.S.-source income or loss.
Key Concepts Glossary
A quick reference guide to the critical anti-abuse and compliance rules governing U.S. inbound transactions. Click each topic to learn more.
Further Resources
This tool is for informational purposes. For detailed guidance, consult official sources and a qualified tax professional.
