Debt And The Profitability Of Foreign Controlled Domestic Corporations In The United States
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Debt And The Profitability Of Foreign Controlled Domestic Corporations In The United States
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Author : Harry Grubert
language : en
Publisher: CreateSpace
Release Date : 2015-01-01
Debt And The Profitability Of Foreign Controlled Domestic Corporations In The United States written by Harry Grubert and has been published by CreateSpace this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-01-01 with categories.
U.S. corporations controlled by foreigners continue to report lower net income in relation to total receipts than comparable domestically-controlled corporations. But the 2004 tax return data show that, in manufacturing and the entire nonfinancial sector, the discrepancy disappears when using a measure of operating income that focuses on the corporations' activities in the United States. To determine operating income, dividends, interest and royalties are subtracted from net income and interest paid, depreciation, amortization, and depletion are added back to net income. Domestically-controlled corporations receive much greater dividend and royalty income, mainly from their subsidiaries abroad.
Studies In International Taxation
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Author : Alberto Giovannini
language : en
Publisher: University of Chicago Press
Release Date : 1993-09-15
Studies In International Taxation written by Alberto Giovannini and has been published by University of Chicago Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 1993-09-15 with Business & Economics categories.
This book presents research on how taxes affect the investment and financing decisions of multinationals. The contributors examine the effects of taxation on decisions about international financial management, business investment, and international income shifting. They consider the influence of tax rules on dividend policy decisions within multinationals; the extent to which tax incentives affect the level and location of research and development across countries; and the fact that foreign-controlled companies operating in the United States pay lower taxes than do domestically controlled companies.
Internal Revenue Bulletin
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Author : United States. Internal Revenue Service
language : en
Publisher:
Release Date : 1964
Internal Revenue Bulletin written by United States. Internal Revenue Service and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1964 with Tax administration and procedure categories.
A consolidation of all items of a permanent nature published in the weekly Internal revenue bulletin, ISSN 0020-5761, as well as a cumulative list of announcements relating to decisions of the Tax Court.
Description Of Revenue Provisions Contained In The President S Fiscal Year Budget Proposal
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Author :
language : en
Publisher:
Release Date : 2010
Description Of Revenue Provisions Contained In The President S Fiscal Year Budget Proposal written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010 with Budget categories.
Tax Havens International Tax Avoidance And Evasion
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Author : Jane Gravelle
language : en
Publisher: DIANE Publishing
Release Date : 2009
Tax Havens International Tax Avoidance And Evasion written by Jane Gravelle and has been published by DIANE Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Banks and banking, International categories.
Description Of Revenue Provisions Contained In The President S Fiscal Year 2010 Budget Proposal Provisions Related To The Taxation Of Cross Border Income And Investment
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Author : United States. Congress. Joint Committee on Taxation
language : en
Publisher:
Release Date : 2009
Description Of Revenue Provisions Contained In The President S Fiscal Year 2010 Budget Proposal Provisions Related To The Taxation Of Cross Border Income And Investment written by United States. Congress. Joint Committee on Taxation and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Budget categories.
Description Of Revenue Provisions Contained In The President S Fiscal Year 2010 Budget Proposal
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Author : United States. Congress. Joint Committee on Taxation
language : en
Publisher: Government Printing Office
Release Date :
Description Of Revenue Provisions Contained In The President S Fiscal Year 2010 Budget Proposal written by United States. Congress. Joint Committee on Taxation and has been published by Government Printing Office this book supported file pdf, txt, epub, kindle and other format this book has been release on with categories.
Joint Committee Print Description Of Revenue Provisions Contained In The President S Fiscal Year 2010 Budget Proposal Part One September 2009
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Author :
language : en
Publisher:
Release Date : 2009
Joint Committee Print Description Of Revenue Provisions Contained In The President S Fiscal Year 2010 Budget Proposal Part One September 2009 written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with categories.
Description Of Revenue Provisions Contained In The President S Fiscal Year 2010 Budget Proposal Part Three Provisions Related To The Taxation Of Cross Border Income And Investment September 2009 Joint Committee Print
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Author :
language : en
Publisher:
Release Date : 2009
Description Of Revenue Provisions Contained In The President S Fiscal Year 2010 Budget Proposal Part Three Provisions Related To The Taxation Of Cross Border Income And Investment September 2009 Joint Committee Print written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with categories.
Tax Havens
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Author : Jane G. Gravelle
language : en
Publisher: Createspace Independent Pub
Release Date : 2013-02-12
Tax Havens written by Jane G. Gravelle and has been published by Createspace Independent Pub this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-02-12 with Business & Economics categories.
Recent actions by the Organization for Economic Cooperation and Development (OECD) and the G-20 industrialized nations have targeted tax haven countries, focusing primarily on evasion issues. The HIRE Act (P.L. 111-147) included a number of anti-evasion provisions, and P.L. 111-226 included foreign tax credit provisions. Some of these proposals, and some not adopted, are in the American Jobs and Closing Loopholes Act (H.R. 4213); the Stop Tax Haven Abuse Act (S. 506, H.R. 1265); draft proposals by the Senate Finance Committee; two other related bills, S. 386 and S. 569; the Bipartisan Tax Fairness and Simplification Act (S. 3018); and proposals by President Obama. Multinational firms can artificially shift profits from high-tax to low-tax jurisdictions using a variety of techniques, such as shifting debt to high-tax jurisdictions. Since tax on the income of foreign subsidiaries (except for certain passive income) is deferred until repatriated, this income can avoid current U.S. taxes and perhaps do so indefinitely. The taxation of passive income (called Subpart F income) has been reduced, perhaps significantly, through the use of “hybrid entities” that are treated differently in different jurisdictions. The use of hybrid entities was greatly expanded by a new regulation (termed “check-the-box”) introduced in the late 1990s that had unintended consequences for foreign firms. In addition, earnings from income that is taxed can often be shielded by foreign tax credits on other income. On average very little tax is paid on the foreign source income of U.S. firms. Ample evidence of a significant amount of profit shifting exists, but the revenue cost estimates vary from about $10 billion to $60 billion per year. Individuals can evade taxes on passive income, such as interest, dividends, and capital gains, by not reporting income earned abroad. In addition, since interest paid to foreign recipients is not taxed, individuals can also evade taxes on U.S. source income by setting up shell corporations and trusts in foreign haven countries to channel funds. There is no general third party reporting of income as is the case for ordinary passive income earned domestically; the IRS relies on qualified intermediaries (QIs) who certify nationality without revealing the beneficial owners. Estimates of the cost of individual evasion have ranged from $40 billion to $70 billion. Most provisions to address profit shifting by multinational firms would involve changing the tax law: repealing or limiting deferral, limiting the ability of the foreign tax credit to offset income, addressing check-the-box, or even formula apportionment. President Obama's proposals include a proposal to disallow overall deductions and foreign tax credits for deferred income and restrictions on the use of hybrid entities. Provisions to address individual evasion include increased information reporting and provisions to increase enforcement, such as shifting the burden of proof to the taxpayer, increased penalties, and increased resources. Individual tax evasion is the main target of the HIRE Act, the proposed Stop Tax Haven Abuse Act, and the Senate Finance Committee proposals; some revisions are also included in President Obama's plan.