James Hardy, the largest U.S. home bias sellers, today announced that its Board of Directors has decided to seek a two-stage plan to modify into a Societas EUROPAEA (SE), some European companies are relatively new in the form of James Hardie shareholders' approval (Phase 1) and then registered to Ireland from the Netherlands (second stage), the company has been reviewing for some time home and business to solve this problem is an important priority is to count. James Hardie Chairman Michael Hammes, out driving in a statement has been a major factor in the review. In the company's decision a major factor, he explained, include:
With global responsibility for the key senior management personnel need to be able to spend with James Hardy's business and its markets more time and
In June 2008, asserted that the United States Internal Revenue Service (IRS), James Hardy are not eligible for benefits under the United States and the Netherlands between 2006 and 2007 (US / Netherlands treaty) tax treaty. Although the company ultimately prevailed, the IRS can later time reiterated its position, so now James Hardy thought it prudent to reduce further disputes with the IRS risk.
Statement, James Hardie is the intellectual property rights and treasury from the Netherlands and financial operations, after December 31, 2010 after the expiration of favorable tax incentives, the company currently enjoys in the Netherlands under financial risk reserves. Mr. Hammes explained that the proposals and intellectual property, capital and financial operations to Ireland (collectively referred to as transactions) constitute the current best practices and James Hardy and James Hardy shareholders.Hammes emphasize the best interests of the decision to relocate to love Ireland's basic factors:
Unlike the US / Netherlands treaty between the United States and Ireland (USA / Ireland treaty) does not contain the "substantial presence test", with global responsibility need to key senior management time spent in Ireland most of the tax agreement, so that these managers Flower and James Hardy's business and its markets have more time, it provides greater certainty James Hardy made under the United States / Ireland treaty benefit ratio is based on the US / Netherlands treaty case, it increases the company's flexibility to take under Irish company law, the Directors consider to expand the company's future strategic options a number of transactions, it simplifies the company's directors to the board governance structure, which makes the company's intellectual property and financial services and treasury qualifications statutory tax rate that is lower than the present situation, if these operations are still in the Netherlands after the expiry of the financial risk reserve system; final
It allows the majority of shareholders are not entitled to receive dividend withholding tax.
The company's statement, in determining the recommendation of the shareholders, James Hardie's directors, senior management and professional advisers to explore a range of options, including retaining the parent company in the Netherlands or moving the United States, Australia or elsewhere in Europe also noted.
"Determined not to pursue moving to the United States or Australia due to, among other reasons, the potential tax consequences for shareholders, the additional complexity of James Hardie's corporate structure and practical considerations, as a minimum acceptance of 95 held by the shareholders to ask the director issued Equity% "end Hammes.
With global responsibility for the key senior management personnel need to be able to spend with James Hardy's business and its markets more time and
In June 2008, asserted that the United States Internal Revenue Service (IRS), James Hardy are not eligible for benefits under the United States and the Netherlands between 2006 and 2007 (US / Netherlands treaty) tax treaty. Although the company ultimately prevailed, the IRS can later time reiterated its position, so now James Hardy thought it prudent to reduce further disputes with the IRS risk.
Statement, James Hardie is the intellectual property rights and treasury from the Netherlands and financial operations, after December 31, 2010 after the expiration of favorable tax incentives, the company currently enjoys in the Netherlands under financial risk reserves. Mr. Hammes explained that the proposals and intellectual property, capital and financial operations to Ireland (collectively referred to as transactions) constitute the current best practices and James Hardy and James Hardy shareholders.Hammes emphasize the best interests of the decision to relocate to love Ireland's basic factors:
Unlike the US / Netherlands treaty between the United States and Ireland (USA / Ireland treaty) does not contain the "substantial presence test", with global responsibility need to key senior management time spent in Ireland most of the tax agreement, so that these managers Flower and James Hardy's business and its markets have more time, it provides greater certainty James Hardy made under the United States / Ireland treaty benefit ratio is based on the US / Netherlands treaty case, it increases the company's flexibility to take under Irish company law, the Directors consider to expand the company's future strategic options a number of transactions, it simplifies the company's directors to the board governance structure, which makes the company's intellectual property and financial services and treasury qualifications statutory tax rate that is lower than the present situation, if these operations are still in the Netherlands after the expiry of the financial risk reserve system; final
It allows the majority of shareholders are not entitled to receive dividend withholding tax.
The company's statement, in determining the recommendation of the shareholders, James Hardie's directors, senior management and professional advisers to explore a range of options, including retaining the parent company in the Netherlands or moving the United States, Australia or elsewhere in Europe also noted.
"Determined not to pursue moving to the United States or Australia due to, among other reasons, the potential tax consequences for shareholders, the additional complexity of James Hardie's corporate structure and practical considerations, as a minimum acceptance of 95 held by the shareholders to ask the director issued Equity% "end Hammes.
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