1- Discuss the Twin objectives of Taxation and the impact of Double Taxation. please apply on the Case of Sigma Corporation

2- How might Sigma use transfer pricing strategies? How do import duties affect transfer pricing strategies?

3- Discuss how a MNC Repatriate blocked funds from a Host Country?

4- Based on the case, what would be your recommendation:

a- To open a small foreign branch or to start a wholly owned Subsidiary

b- to choose the location in Spain or Cyrus.

Sigma Corp.'s Location Decision Sigma Corporation of Boston is contemplating establishing an affiliate operation in the Mediterranean. Two countries under consideration are Spain and Cyprus. Sigma intends to repatriate all after-tax foreign-source income to the United States. In the U.S., corporate income is taxed at 35 percent. At this point, Sigma is not certain whether it would be best to establish the affiliate operation as a branch operation or a wholly owned subsidiary of the parent firm. In Cyprus, the marginal corporate tax rate is 15 percent. Foreign branch prof- its are taxed at the same rate. In Spain, corporate income is taxed at 30 percent. Additionally, foreign branch income in Spain is also taxed at 30 percent. The with- holding tax treaty rates with the U.S. on dividend income paid from Cyprus is 5 percent and 10 percent paid from Spain. The financial manager of Sigma has asked you to help him determine where to locate the new affiliate and which organizational structure to establish. The location decision will be largely based on whether the total tax liability would be smallest for a foreign branch or a wholly owned subsidiary in Cyprus or Spain