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Technology Stocks : WDC/Sandisk Corporation
WDC 174.21+6.9%3:59 PM EST

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To: Bryan V who wrote (2709)3/27/1998 10:55:00 AM
From: Jerome Wittamer  Read Replies (1) of 60323
 
I am no US tax expert, however see my profile for more info

Here's what I do know :

IMHO you are correct in assuming that goind forward SanDisk's pretax income will bear the full fed tax rate of 35%.

Indeed the company has used almost all its available tax credits. However, given the expansion of its facilities and R&D operations one can expect that some of the tax burden would be aleviated.

As regards the revenues from abroad :

it depends on how the company has structured sales :

direct sales thru US, sales thru foreign branches, sales thru foreign subsidiaries (here there's a difference between opaque subsidiaries and transparent subsidiaries).

It also very much depends on the location of these foreign entities and on the existence and nature (favourable or not) of double tax treaties concluded between the US and the foreign country.

A classic scenario would be the following :

sales in Japan thru Japanese subsidiary : SanDisk Tokyo Ltd would be taxable on its revenues in Japan and would repatriate its profits under the form of either interests, dividends, royalties, ...(i.e. the one most tax friendly)

those distributions would likely bear a withholding tax in Japan
SanDisk US would be taxable on those profits in the US but would be able to credit Japanese WHT on the US tax corresponding to those revenues.

It's not as simple as that but at least you have an idea. Do not hesitate to post me private as I suppose few people are interested in such bla-bla.

Said briefly, their tax regime depends on how seasoned their tax advisors are.
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