Dive Brief:

• Wal-Mart Stores Inc. has a network of subsidiaries and branches not mentioned anywhere in its Securities and Exchange Commission filings and is sheltering some $76 billion in assets, according to a report by the United Food & Commercial Workers International Union.

• The units in low-tax places like Luxembourg enable the retailer to trim its tax obligations to the U.S. by some $3.5 billion, the report found.

• In response to the report, Wal-Mart said it was “designed to mislead” and that the company has “processes in place to comply with applicable SEC and IRS rules, as well as the tax laws of each country where we operate.”

Dive Insight:

Certainly the United Food & Commercial Workers International Union may have an ax to grind: the union files suits and complaints in court and with regulatory agencies all the time on the behalf of Wal-Mart employees. But its report could be a handy starting point for others, including the U.S. and foreign governments, to look into the retailer’s tax policies further.

Indeed, the European Commission in particular has grown impatient with U.S. companies, notably Amazon, that structure themselves to avoid taxes.