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The U.S. As Tax Haven? Aiding Developing Countries By Revoking The Revenue Rule, Samuel D. Brunson
The U.S. As Tax Haven? Aiding Developing Countries By Revoking The Revenue Rule, Samuel D. Brunson
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Over the years, many OECD countries, including the United States, have identified tax havens as a significant problem, and have acted to limit the ability of their taxpayers to use tax havens to reduce their taxes. The United States has implemented tax regimes, including subpart F and the passive foreign investment company rules, and disclosure regimes, such as the recently-enacted FATCA rules, to prevent U.S. taxpayers from taking advantage of tax haven jurisdictions.
But the intersection of a number of U.S. tax rules, it turns out, makes the United States an attractive place for foreigners to invest—and hide …