As companies continue to permanently reinvest their earnings offshore, it brings forth a reminder that when valuing a non-U.S. entity for U.S. tax purposes, one must be cognizant of the company's position on permanent reinvestment, as it will affect the tax rate that is assumed in the valuation of the entity.  

Applying a tax rate that is consistent with the company's position is vital in valuing the entity - (e.g. if they have a deferred tax liability due to not permanently reinvesting, a U.S. tax rate should be applied).