Wealth Repatriation In The Reintegration Of Offshore Wealth Analysis

We examine the effects of transfer pricing on shareholders of multinational corporations and the United States government through a case study on Apple. Apple was able to successfully dodge billions of taxes in the U.S. through the use of aggressive transfer pricing with their Irish subsidiaries. We found that Apple was never fined by the IRS because they were exploiting a loophole in the arm’s length principle. While shareholders stand to profit from aggressive transfer pricing practices, they must be aware of the risk that aggressive transfer pricing imposes and be aware of companies’ motivations and morals for engaging in transfer pricing.

With the advancements in the globalization of the economy, corporations are finding more ways to avoid the extraordinary tax rates set in place of The United States Of America. With the loss of revenue from large companies dodging taxes the government must make up for the loss by either raising taxes or changing the tax code. A recent company to avoid american taxes is Johnson Controls, a company that “…would not exist as it is today but for American taxpayers, who paid $80 billion in 2008…”(The Editorial Board). This use of American resources to get through tough times, and run to another county during an economic incline is an act that calls for reform in the American tax system. However congress has not passed any legislation to fix the

However, the companies only have to pay the U.S. tax for foreign revenues once they bring the profits back to the United States. As a result of these current tax laws, U.S. companies that seek to avoid high corporate tax rates hold their foreign earned profits overseas. “It just makes no sense to pay a substantial tax on it,” said Joseph Kennedy, a senior fellow at the Information Technology and Innovation Foundation (Rubin, R.). It is far too easy for an IT corporation to create a patent in a foreign country and direct revenue to a corporation within that country, thus avoiding the much higher U.S. tax rates. According to Joint Committee on Taxation estimates, the lost revenue is increasing over time as corporations find even more creative ways to make their U.S. profits look like offshore income (Richards, K., & Craig, J.). As result, multinational American corporations have as much as $2 trillion held in overseas subsidiaries and if brought into the United States with the current tax laws, the federal government could benefit by nearly $50 billion per year.

The less taxes we pay, the more lives we save. The United States has the highest corporate tax rate of the 34 developed, free market nations that make up the Organization for Economic Cooperation and Development (DECD). Unlike other countries, the United States pays a marginal corporate tax rate of 35% at the federal level and 39.2% state taxes are accounted. This is causing thousands of corporations to move operations out of the United States and into other countries. Therefore, the United States should lower the taxes of big corporations.

The main objective of many companies is to minimize their tax obligations. Jeffers (2014) discussed the reason of why companies adopt tax inversion strategies. The researcher indicated that the income maximization is a major reason of companies attempting to reduce their tax liability (pp. 100-101). Tax inversion strategies provide companies an advantage to lower income tax rate. Today, U.S. corporations renounce its U.S. citizenship and move to low-tax countries. Companies that reincorporate oversees are not obligated to pay U.S. taxes on earning income (p. 99). Many countries implement tax competition strategies to attract and retain businesses. Well-known companies, such as Exxon Mobil, Hewlett Packard, Tyco, General Electric, PepsiCo, etc. take benefits of tax shelter opportunities overseas (p. 102). Other benefits of the jurisdiction abroad are flexible banking laws and simplified litigation processes.

The last major reform of U.S. tax law took place in 1986. The complaints involved an individual tax rate of 39.6% and a corporate tax rate of 35%, which led to distortions due to loopholes, exploitation, and the increasing difficulty of national authorities in taxation. The complexity of transnational corporations in the global context account of the disorganization and transfer pricing of enterprises.

To obtain long term solutions it is critical that the American government reshapes the tax code and provides Americans a substantial amount of tax relief. The current tax code is too complicated, it needs to be simplified. The way the current tax code is organized it seems that it someone needs an advanced degree in order to effectively understand and complete it. Simplifying the tax code will be beneficial to the average citizen and the government. This country needs to effectively increase the economic developments within its boundaries. To allow substantial economic development this government is absolutely necessary that this country put an end to corporate inversion. The biggest factors that contribute to corporate inversion are the incredibly high tax rate of thirty five percent and the decision by the American government to force a tax on company’s income, regardless of their location. By lowering the corporate tax rate and allowing to America to transition from an international system to a more domestic one, corporate inversion will end which will add a enormous amount money back into the American economy. These long term solutions will give America permanent solutions to the horrible tax problems it faces

Many large corporations are not paying their fair share of taxes, including what is legally required of them. They use tax breaks, loop holes, and so on. Many corporations pay no federal income taxes at all, stashing their cash in off shore tax havens around the world… causing us to lose over $100 billion a year in revenue.

“Panama Papers: The Real Scandal Is What’s Legal” by Brooke Harrington was written on April 6th, 2016 and published in ‘The Atlantic’. In this article, Harrington stresses the idea that tax avoidance and offshore finances are entangled with the acts of many governments seeing that it is what stabilizes the economic growth of a country. The author discusses the link between the Panamanian wealth management firm Mossack Fonesca, to a numerous amount of financial crimes. The “Panama Papers” are documents that consist of firms who are allegedly involved in fraud, money laundering, and theft. No country would even think to create strict laws towards ending tax evasion because it would hurt several economies and firms like Mossack Fonesca whose

A business owner that is generating excess cash on top of what they require to survive can take advantage of a tax deferral that is not available to salaried employees. The excess income generated can be invested in passive investments within the corporation. Since the excess income has been taxed at a lower corporate rate, this leaves more funds available for investment which allows for a higher level of compounding as well. Salaried employees are not in a position to be able to defer tax on an unlimited amount of income. Even though the business owner will eventually have to pay themselves dividends, Ottawa feels this deferral advantage gives them an unfair advantage over salary-earning Canadians.

In addition to allowing corporations to store billions of untaxed dollars, tax havens are also used to support dictators and undemocratic societies. All dictators like Muammar Gaddafi have had billions of dollars stashed in tax havens all around the world. “Tax havens are also used as the principal route through which laundered money escapes developing countries.” (Palan)

Similarly, the administration has introduced a one-time tax to be imposed on trillions that are held in the Diaspora. With this tax, the government hopes to encourage corporations to bring back the finances home and invest more in the nation in order to take advantage of the lower corporate tax. The administration hopes to cover these changes in the tax regime by eliminating deductions and several loopholes that have long favored the very rich, special interests, and exemptions on interest accruing from life insurance, particularly for those in the high-income bracket (Nunns, Burman, Rohaly & Rosenberg, 2016).

What the author, Pat Regnier, is saying in his work “Everything You Need to Know About Companies Leaving America for Taxes” is that large American companies are abandoning their American domain and hanging Uncle Sam out to dry just to save on tax cuts. To be more direct, the author argues that these companies are taking over smaller corporations where tax rates are lower than in the US. They do this over and over again till they find a suitable location to “safely”escalate their profits. He writes, “The large American company is now a foreign one, and taxed accordingly.” In this section of the author’s argument, Pat is suggesting that there is a “loophole” in the American tax system and it is creating all kinds of havoc, domestically and abroad. Putting it all together, the author`s belief is even though outsourcing is attractive, it is equally chaotic as it is beneficial.

The United States is in a recession; it has been facing some of the worse economic times since the Great Depression in the 1930’s. One option to fix the economy is to change the corporate tax rate. To lower it or to raise it, that is the question economists have been speculating. America's high corporate tax rate and worldwide system of taxation discourages U.S. companies from sending their foreign-source revenue home, which makes U.S. companies defenseless to foreign acquisition from the international opponents (Camp). Corporations and United States citizens have been fighting for a tax reform, which would hopefully help the American economy; either by lowering the corporate tax, or by raising the tax.

The actions of multinational corporations (MNCs), which derive from their morally dubious goals, may be completely legitimate within a capitalist society. One of these actions that will be examined in this essay is the use of tax havens, as a way of avoiding higher tax liability. This paper will utilise the case study of Apple’s tax avoidance, in examining the legitimation of a company’s goal of profit maximisation, a goal that is against the moral/social consensus