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Full-Text Articles in Law
Attacking Profit Shifting: The Approach Everyone Forgets, Jeffrey M. Kadet
Attacking Profit Shifting: The Approach Everyone Forgets, Jeffrey M. Kadet
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No abstract provided.
Fair Approaches For Taxing Previously Untaxed Foreign Income, Jeffrey M. Kadet
Fair Approaches For Taxing Previously Untaxed Foreign Income, Jeffrey M. Kadet
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In connection with any transition to a new international tax system, we need an approach that effectively deals with the trillions of dollars of previously untaxed foreign income held by CFCs. There is logic and fairness in applying a rate on those earnings that is less than the 35 percent home country rate because the rules of the game are being changed significantly.
Many U.S. multinationals have had legitimate commercial reasons for retaining their earnings overseas. For these, I can happily accept whatever rate Congress chooses, whether it is at the lower 3.5 percent level of TRA 2014, the 14 …