Asian Automaker-Finance Company
Mr. Cope advised a foreign automaker in connection with the transition of certain finance-related business activities from its U.S. finance subsidiary to a non-U.S. subsidiary. The advice concerned whether the non-U.S. finance subsidiary would be exposed to U.S. tax as a result of its business relationships. The issues considered included whether the non-U.S. subsidiary was engaged in U.S. trade or business and whether it was entitled to the benefits of the applicable income tax treaty with the United States.