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Corporate inversion; controlled foreign corporation; international taxation; U.S.-sourced income; foreign-sourced income; merger; worldwide income; territorial income
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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 …