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.
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.
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.
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.
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. 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.
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
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.
Publisher: Createspace Independent Publishing Platform
ISBN: 9781977844361
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.
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
Publisher:
ISBN:
Category :
Languages : en
Pages : 40
Book Description
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 : Corporations, American
Languages : en
Pages : 648
Book Description
Publisher:
ISBN:
Category : Corporations, American
Languages : en
Pages : 648
Book Description
U.S. Tax Guide for Aliens
U.S. Investment Since the Tax Cuts and Jobs Act of 2017
Author: Emanuel Kopp
Publisher: International Monetary Fund
ISBN: 1498317049
Category : Business & Economics
Languages : en
Pages : 37
Book Description
There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S. business investment since 2017 has grown strongly compared to pre-TCJA forecasts and that the overriding factor driving it has been the strength of expected aggregate demand. Investment has, so far, fallen short of predictions based on the postwar relation with tax cuts. Model simulations and firm-level data suggest that much of this weaker response reflects a lower sensitivity of investment to tax policy changes in the current environment of greater corporate market power. Economic policy uncertainty in 2018 played a relatively small role in dampening investment growth.
Publisher: International Monetary Fund
ISBN: 1498317049
Category : Business & Economics
Languages : en
Pages : 37
Book Description
There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S. business investment since 2017 has grown strongly compared to pre-TCJA forecasts and that the overriding factor driving it has been the strength of expected aggregate demand. Investment has, so far, fallen short of predictions based on the postwar relation with tax cuts. Model simulations and firm-level data suggest that much of this weaker response reflects a lower sensitivity of investment to tax policy changes in the current environment of greater corporate market power. Economic policy uncertainty in 2018 played a relatively small role in dampening investment growth.
OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS
Author: OECD
Publisher: OECD Publishing
ISBN: 9264278796
Category :
Languages : en
Pages : 104
Book Description
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).
Publisher: OECD Publishing
ISBN: 9264278796
Category :
Languages : en
Pages : 104
Book Description
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).
Corporate Income Taxes under Pressure
Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1513511777
Category : Business & Economics
Languages : en
Pages : 388
Book Description
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Publisher: International Monetary Fund
ISBN: 1513511777
Category : Business & Economics
Languages : en
Pages : 388
Book Description
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.