The Resource The GAAP lock-out effect and the investment behavior of multinational firms

The GAAP lock-out effect and the investment behavior of multinational firms

Label
The GAAP lock-out effect and the investment behavior of multinational firms
Title
The GAAP lock-out effect and the investment behavior of multinational firms
Creator
Subject
Language
  • eng
  • eng
Summary
The taxation by the United States of controlled foreign corporations (CFCs) of US multinational firms has been the subject of an ongoing debate since the enactment of the CFC rules of subpart F in 1962. Generally, the US does not tax active earnings of CFCs - earnings that are generated through the business operations of the CFCs abroad - when earned. The US taxation of these earnings is deferred until their repatriation to the US. This article looks into the investment behaviour of multinational firms with respect to earnings of their foreign subsidiaries. It provides a brief and general overview of basic concepts of international taxation, discusses the development of theoretical insights of the economics literature regarding the relevance of the repatriation tax to the repatriation behaviour of MNEs, and discusses the GAAP indefinite reversal exception and its lock-out effect on CFC earnings
Citation source
In: Tax law review. - New York. - Vol. 67 (2014),
http://library.link/vocab/creatorName
Shaheen, F
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • foreign source income
  • GAAP
  • MNE
  • deferral
  • repatriation
Label
The GAAP lock-out effect and the investment behavior of multinational firms
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2014/T/TAXLARE/2_211-248.zip
Publication
Note
20141013

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