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- Corporate inversion; controlled foreign corporation; international taxation; U.S.-sourced income; foreign-sourced income; merger; worldwide income; territorial income (1)
- International taxation; the European Commission; worldwide tax system; territorial tax system; domestic-sourced income; foreign-sourced income (1)
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Full-Text Articles in Business Analytics
Abuses And Penalties Of A Corporate Tax Inversion, James G.S. Yang, Leonard J. Lauricella Professor, Frank J. Aquilino
Abuses And Penalties Of A Corporate Tax Inversion, James G.S. Yang, Leonard J. Lauricella Professor, Frank J. Aquilino
Department of Accounting and Finance Faculty Scholarship and Creative Works
There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as “corporate tax inversion”. This paper discusses the abuses and penalties of this phenomenon. It is rooted in some deficiencies in the U.S. tax law. This paper points out that the U.S. has the highest corporate tax rate in the world. It imposes tax on worldwide income. It permits deferral of tax on …
The Emerging International Taxation Problems, James G. Yang, Victor N.A. Metallo
The Emerging International Taxation Problems, James G. Yang, Victor N.A. Metallo
Department of Accounting and Finance Faculty Scholarship and Creative Works
The problems of tax evasion and tax avoidance are as old as taxes themselves. Between 2015 and 2016 alone, many U.S. multinational corporations were involved in tax disputes with the European Commission. From a historical perspective, these disputes are unprecedented as they have resulted in tremendous amount of tax penalties. The most notable case was Apple for €13 billion of unpaid tax. This article discusses what tax strategies these corporations used that caused such disputes. It specifically investigates seven corporations: Apple Inc., McDonald’s, Starbucks, Fiat, Amazon, Google, and Ikea, and elaborates on the following tax strategies: high royalties, intercompany transfer …