The Resource Corporate inversion strategies versus anti-inversion Treasury Regulations

Corporate inversion strategies versus anti-inversion Treasury Regulations

Label
Corporate inversion strategies versus anti-inversion Treasury Regulations
Title
Corporate inversion strategies versus anti-inversion Treasury Regulations
Creator
Subject
Language
eng
Summary
International trade was intended to promote economic efficiency on a global scale. However, like most good intentions, there are unintended consequences. Many U.S. multi-national corporations earned profits abroad but never remitted dividends back to the United States. This amounted to approximately $2 trillion by 2014, which results in a loss of $20 billion in the U.S. tax revenue. Worse yet, many corporations even renounced their U.S. citizenships and moved abroad, bringing with them their U.S. tax base. This kind of loss is even more devastating because it is a permanent loss. In fact, 76 corporations have actually done so in the past two decades. The trend is becoming more serious and abusive. This movement in the arena of international taxation is known as "corporate inversion". What are the reasons contributing to this debacle? What strategies did these corporations employ? Did the U.S. Treasury take any action to stop it? In fact, it has prompted the U.S. Congress to enact Code Sec. 7874, the IRS to issue Notices 2014-52 and 2015-79, and the U.S. Treasury to promulgate T.D. 9761. What do these regulations intend to accomplish? This article attempts to answer these questions
Citation source
In: Taxes - the tax magazine. - Riverwoods. - Vol. 94 (2016), no. 8 ; p. 47-53
http://library.link/vocab/creatorName
  • Yang, J.G.S
  • Aquilino, F.J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • corporate inversion
  • anti-inversion
  • domicile
  • worldwide income
  • territoriality principle
  • deferral
  • CFC
  • intercompany loan
  • profit shifting
  • losses
Label
Corporate inversion strategies versus anti-inversion Treasury Regulations
Instantiates
Publication
Label
Corporate inversion strategies versus anti-inversion Treasury Regulations
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...