4 ms·
How? Corporate mergers appear to be an intrinsically available strategy for avoiding an extraterritorial corporate tax system. What intervention will your legis
by vezzy-fnord 11y ago
How? Corporate mergers appear to be an intrinsically available strategy for avoiding an extraterritorial corporate tax system. What intervention will your legislative pen impose?
- toomuchtodo 11y ago> Corporate mergers appear to be an intrinsically available strategy for avoiding an extraterritorial corporate tax system. ...because of legislation and existing tax code allowing it. > What intervention will your legislative pen impose? I would have to speak with a legal associate with experience drafting legislation for specific language. The purposes would be to ensure any tax intended to specifically be avoided by a merger would be re-captured (this isn't out of the ordinary; the AMT in the US is specifically designed to disallow certain income tax deductions when a taxpayers income reaches a certain level, to prevent tax avoidance). My understanding is that the Double Irish Arrangement "loophole" has been closed, but further work needs to be done.
- vezzy-fnord 11y agoSo, the business purpose and economic substance doctrines. Again, flimsy normative statements. A legislative pen obsessed with maximizing such a function will eventually write things unsavory to civil liberties, as well.