Corporate Inversions

The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.

The U.S. corporate income tax is based on worldwide economic activity. If all of a corporation's economic activity is in the United States, then tax administration and compliance is, relatively, straight-forward. Many corporations, however, operate in several jurisdictions, which creates complications for tax administration and compliance. Further, corporations may actively choose where and how to organise to reduce their U.S. and worldwide tax liabilities. Some of these strategies have been referred to as expatriation, inversions, and mergers. This book examines them in light of recent expansion of their use and growing congressional interest. This book also focuses on the global issues relating to tax rate differentials between the United States and other countries. It provides tax rate comparisons; discusses policy implications, including the effect of a corporate rate cut on revenue, output, and national welfare; and discusses the outlook for and consequences of a revenue neutral corporate tax reform.

In May 2019, the Inclusive Framework adopted a Programme of Work, which was endorsed by the G20 Finance Ministers and G20 Leaders in June 2019. The Programme of Work outlined proposals in two pillars that could form the basis for a multilateral consensus-based solution. This report presents an ex ante analysis of the economic and tax revenue implications of the Pillar One and Pillar Two proposals under discussion by the Inclusive Framework as part of its work to address the tax challenges arising from the digitalisation of the economy.

How America was Tricked on Tax Policy explains how regular citizens were “tricked” by the outdated view of economists that much heavier taxation of labor rather than capital is economically justifiable. The truth is that workers pay their taxes while the rich pay very little. Based on reputable sources of information, including publications of the Organization for Economic Cooperation and Development (OECD), official statistics data, and the publications in high-ranked journals, the book paves the way for a new policy-making process aimed to achieve more sustainable taxation and to increase the wellbeing of citizens as the main goal of any modern state policy. Dealing with critically important and underexplored topics in tax policy, the book challenges an enshrined dogma that is rarely challenged at the level of policy. In doing so, this book envisions policy changes that could be highly impactful in a new political administration. This book proposes that governments should look for not just corporate income tax rate reduction when announcing their tax reforms but should equally focus on the reduction of the overall tax burden on labor. The negative impact and high social cost of wage taxation is exemplified by the key areas of tax policy that are relevant for every wealthy state, such as taking due care of public health, investing in education and wellbeing of children, and supporting small business for the overall benefit to society. The book compellingly argues how tax policy could be improved by incorporating science and scientific methods.