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Offshore Profit Shifting and the U.s. Tax Code

Author: United States Congress
Publisher: Createspace Independent Publishing Platform
ISBN: 9781977839497
Category :
Languages : en
Pages : 304

Book Description
Offshore profit shifting and the U.S. Tax Code. Part 2 (Apple Inc.) : hearing before the Permanent Subcommittee on Investigations of the Committee on Homeland Security and Governmental Affairs, United States Senate, One Hundred Thirteenth Congress, first session, May 21, 2013.

Offshore Profit Shifting and the U.s. Tax Code

Author: United States Congress
Publisher: Createspace Independent Publishing Platform
ISBN: 9781977839497
Category :
Languages : en
Pages : 304

Offshore Profit Shifting and U. S. Tax Code Weaknesses

Author: Reny Toupin
Publisher: Nova Science Publishers
ISBN: 9781628084795
Category : Corporations, American
Languages : en
Pages : 0

Book Description
On 21 May 2013, the Permanent Subcommittee on Investigations (PSI) of the U.S. Senate Homeland Security and Government Affairs Committee held a hearing that was a continuation of a series of reviews conducted by the Subcommittee on how individual and corporate taxpayers are shifting billions of dollars offshore to avoid U.S. taxes. This book examines those hearings and how Apple Inc., a U.S. multinational corporation, has used a variety of offshore structures, arrangements, and transactions to shift billions of dollars in profits away from the United States and into Ireland, where Apple has negotiated a special corporate tax rate of less than two percent. This book examines how Apple Inc. transferred the economic rights to its intellectual property through a cost sharing agreement with its own offshore affiliates, and was thereby able to shift tens of billions of dollars offshore to a low tax jurisdiction and avoid U.S. tax. Apple Inc then utilised U.S. tax loopholes, including the so-called "check-the-box" rules, to avoid U.S. taxes on $44 billion in taxable offshore income over the past four years, or about $10 billion in tax avoidance per year. The book also examines some of the weaknesses and loopholes in certain U.S. tax code provisions, including transfer pricing, Subpart F, and related regulations, that enable multinational corporations to avoid U.S. taxes.

Re: Offshore Profit Shifting and the U.S. Tax Code

Author: United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations
Publisher:
ISBN:
Category :
Languages : en
Pages : 40

Book Description

Offshore Profit Shifting and the U. S. Tax Code. Part 1 (Microsoft and Hewlett-Packard)

Author: United States. Congress
Publisher: Createspace Independent Publishing Platform
ISBN: 9781981769520
Category :
Languages : en
Pages : 644

Book Description
Offshore profit shifting and the U.S. Tax Code. Part 1 (Microsoft and Hewlett-Packard) : hearing before the Permanent Subcommittee on Investigations of the Committee on Homeland Security and Governmental Affairs, United States Senate, One Hundred Twelfth Congress, second session, September 20, 2012.

Offshore Profit Shifting and the U.s. Tax Code

Author: United States. Congress
Publisher: Createspace Independent Publishing Platform
ISBN: 9781977844361
Category :
Languages : en
Pages : 644

Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle

Author: Eva Escribano
Publisher: Kluwer Law International B.V.
ISBN: 940350644X
Category : Law
Languages : en
Pages : 249

Book Description
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.

Offshore Profit Shifting and the U. S. Tax Code

Book Description

Caterpillar's Offshore Tax Strategy

Book Description

International Taxation and the Extractive Industries

Author: Philip Daniel
Publisher: Routledge
ISBN: 1317330137
Category : Business & Economics
Languages : en
Pages : 382

Book Description
The taxation of extractive industries exploiting oil, gas, or minerals is usually treated as a sovereign, national policy and administration issue. This book offers a uniquely comprehensive overview of the theory and practice involved in designing policies on the international aspects of fiscal regimes for these industries, with a particular focus on developing and emerging economies. International Taxation and the Extractive Industries addresses key topics that are not frequently covered in the literature, such as the geo-political implications of cross-border pipelines and the legal implications of mining contracts and regional financial obligations. The contributors, all of whom are leading researchers with experience of working with governments and companies on these issues, present an authoritative collection of chapters. The volume reviews international tax rules, covering both developments in the G20-OECD project on ’Base Erosion and Profit Shifting’ and more radical proposals, identifying core challenges in the extractives sector. This book should become a core resource for both scholars and practitioners. It will also appeal to those interested in international tax issues more widely and those who study environmental economics, macroeconomics and development economics.

Taxation in a Global Digital Economy

Author: Ina Kerschner
Publisher: Linde Verlag GmbH
ISBN: 3709409047
Category : Law
Languages : en
Pages : 467

Book Description
Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.