How Obama will use transfer pricing to cut US deficit
September 27, 2011
Sophie Ashley
President Obama’s tax reform proposals for the US include transfer pricing provisions which promise to reduce the nation’s deficit by $24 billion over 10 years.
“Notwithstanding the transfer pricing rules,” said the reform proposal, “there is evidence of income shifting offshore, including through transfers of intangible rights to subsidiaries that bear little or no foreign income tax. Under the proposal, if a US parent transfers an intangible to a controlled-foreign corporation (CFC) in circumstances that demonstrate excessive income shifting from the US, then an amount equal to the excessive return would be treated as subpart F income.”
Sorry. You must be a subscriber to view this article. Alternatively, why not take a free trial? To subscribe and access this article immediately simply click here or call +44(0)207 779 8380.