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Friday, November 5, 2010

Miller: How U.S. Tax Law Encourages Investment in Offshore Tax Havens

David S. Miller (Cadwalader, New York) has posted Unintended Consequences: How U.S. Tax Law Encourages Investment in Offshore Tax Havens on SSRN. Here is the abstract:

The Internal Revenue Code is riddled with features that allow U.S. taxpayers to reduce their federal tax liability by operating through tax haven companies. Some of these provisions are historic anomalies. Others are better understood as inadvertent loopholes than considered legislative grace. Some incentives are indeed intentional.

The paper catalogues the many ways that U.S. federal and state tax law encourages taxpayers to operate through foreign tax haven companies to reduce their tax liabilities, and attempts to explain the history and policy underlying the rules. The paper then offers a number of suggestions to eliminate the inadvertent incentives that encourage U.S. taxpayers to form foreign corporations and operate through them solely for tax purposes.

http://taxprof.typepad.com/taxprof_blog/2010/11/miller-.html

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Comments

If true, this article means that Barbara Boxer offshored more jobs than Carly Fiorina. (If you wathed TV in California during the past 3 months, you'd get the joke).

Posted by: guy in the veal calf office | Nov 5, 2010 10:54:50 AM