Tax consolidation

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Tax consolidation, or combined reporting, is a regime adopted in the tax or revenue legislation of a number of countries which treats a group of wholly owned or majority-owned companies and other entities (such as trusts and partnerships) as a single entity for tax purposes. This generally means that the head entity of the group is responsible for all or most of the group's tax obligations (such as paying tax and lodging tax returns). Consolidation is usually an all-or-nothing event: once the decision to consolidate has been made, companies are irrevocably bound. Only by having less than a 100% interest in a subsidiary can that subsidiary be left out of the consolidation.

Contents

The aim of a tax consolidation regime is to reduce administrative costs for government revenue departments and reduce compliance costs for corporate taxpayers. For companies, consolidating can help understate profits by having losses in one group company reduce profits for another. Assets can be transferred between group companies without triggering a tax on gain for the company receiving assets, dividends can be paid between group companies without incurring tax liabilities, and tax attributes of one group company such as imputation credits can be used by other companies in the group. In some jurisdictions there may be other benefits, such as the ability to look through the acquisition of shares of acquired companies to depreciate the underlying assets.

Countries which have adopted a tax consolidation regime include the United States, France, Australia and New Zealand. Countries which do not permit tax consolidation often have rules which provide some of the benefits. For example, the United Kingdom has a system of group relief, which permits profits of one group company to be reduced by losses of another group company.

Consolidation regimes can include onerous rules and regulations. There are typically complex rules to deal with the acquisition of companies with tax losses or other tax attributes. Both the United States and Australia have rules which restrict the use of such losses in the wider group. In Australia, fixed trusts and 100% partnerships can be members of a consolidated group, but the head company must be a company and cannot be a trust or partnership.

United States consolidated returns

United States federal income tax rules permit commonly controlled corporations to file a consolidated return. [1] The income tax and credits of the consolidated group are computed as if the group were a single taxpayer. Intercorporate dividends are eliminated. Once a group has elected to file a consolidated return, all members joining the group must participate in the filing. The common parent corporation files returns, and is entitled to make all elections related to tax matters. The common parent acts as agent for the members, and it and the members remain jointly and severally liable for all federal income taxes. Many U.S. states permit or require consolidated returns for corporations filing federal consolidated returns. [2]

Requirements for filing

Only entities organized in the United States and treated as corporations may file a consolidated Federal income tax return. [3] The return is filed by a “common parent” and only those subsidiaries in which the common parent owns 80% or more of the vote AND value. [4] The parent and all subsidiaries must file Form 1122 to elect to file a consolidated return in the first year of election. [5] Every 80% subsidiary must make the election or it is not valid. Thereafter, all corporations that begin to meet the 80% vote and value test must join in the consolidated return. If a subsidiary ceases to meet the 80% vote and value test, it is removed from the group. Adjustments to basis and other tax attributes apply upon a subsidiary joining or leaving a group. [6]

Consolidated taxable income

Taxable income of each member is computed as if no consolidated return were filed, with the exception of certain items computed on a consolidated basis. [7] Then adjustments are made for certain transactions between group members. [8] Dividends between group members are eliminated. Sales of property between members give rise to a deferred intercompany transaction. [9] The effect on the selling member is deferred and recognized as the corresponding effects are recognized by the buying member. For example, Member A sells Member B some goods at a profit. This profit is not recognized until Member B sells the goods or recognizes depreciation expense on the goods. These complex rules require adjustments related to intra-group sales of property (including depreciable assets and inventory), transactions in stock or other obligations of members, performance of services, entry and exit of members, and certain back-to-back and avoidance transactions.

Certain deductions and most credits are computed on a consolidated rather than separate company basis. [10] These include the deductions for net operating loss, charitable contributions, domestic production activities deduction, dividends received deduction and others.

Each member of a group must recognize gain or loss on disposition of its shares of other members. Such gain or loss is affected by the member's basis in such shares. Basis must be adjusted for several items, including taxable income or loss recognized by the other member, distributions, and certain other items. [11] To the extent a member recognizes losses in excess of the owner's basis, such excess loss is treated as negative basis for all U.S. Federal income tax purposes. Additional adjustments apply in the case of intra-group reorganizations or acquisition of the common parent, [12] and upon entry to or exit from the group by a member. The adjustments “tier up” to consolidated return members who own shares of the entity making the adjustment. Numerous other adjustments apply.

Filing periods

All members of the group must use the same tax year as the common parent. [13] This may be adopted or changed by the common parent. If one group acquires another group, the acquiring common parent's tax year must be adopted by all acquired subsidiaries then meeting the 80% vote and value test. Short periods may be required upon joining or leaving a group. In addition, if a member enters or leaves the group, certain adjustments to earnings and profits, basis, and other tax attributes apply.

Fiscal unity

Several countries allow related groups of corporations to compute income tax on a consolidated basis, in a manner similar to consolidation for financial reporting purposes. This is referred to in the Netherlands and Luxembourg as a Fiscal Unity, and in France as Intégration Fiscale. A similar consolidated return regime applies in Spain. In such systems, consolidating eliminations of income and expense are taken into account.

The Netherlands system allows a group of Netherlands resident corporations and branches of foreign corporations to elect to be taxed as a Fiscal Unity. Such election is permitted only for a parent corporation and its 95% or greater owned subsidiaries. Upon election, the parent is taxed on the combined income of the members of the group. The parent and subsidiaries retain joint and several liability for the tax of the group. [14]

Netherlands fiscal unity functions much like financial statement consolidation. Intra-group transactions, including property transfers, are generally eliminated. Most intra-group reorganizations do not trigger taxable events.

Group relief

Some countries allow losses of one commonly controlled company to offset the profits of another commonly controlled company. The United Kingdom permits group relief, and Germany permits an Organschaft. Neither of these systems involve combined reporting or combined tax return filing, though certain additional reporting may be required. [15]

Under the UK scheme, a company's losses may be surrendered to a related company if several conditions are met. The companies must be 75% owned companies. For this purpose, a parent company and its subsidiaries qualify if the parent company owns at least 75% of the ordinary share capital of the subsidiary(ies) and have a beneficial interest in at least 75% of any distributions of earnings or upon winding up. Alternative similar rules apply for certain consortia and branches. Under European Court of Justice rulings incorporated into UK law, the parent company need not be resident in the UK.

The UK scheme allows losses of one group member to be relieved (deducted) by members using a different accounting period, with certain adjustments. Trading (business) losses, capital losses, certain excess (disallowed) management expenses from non-UK affiliates, and certain excess charges may be relieved, subject to limitations. The surrender of these items is done by one company for the benefit of one other company.

Unitary groups

Some states in the United States require related corporations to file a consolidated return if such corporations constitute a unitary business or unitary group. [16] Such consolidated returns tend to follow the pattern of United States Federal consolidated returns, though differences exist in the particular rules. Generally, a group of corporations in the same, similar, or integrated businesses that are under common management and operational control may be treated as a unitary group.

In a late June, 1983 decision, the US Supreme Court first sanctioned worldwide combined reporting in Container Corp. v. Franchise Tax Board (CA). [17] The years in question were 1963-1965 and the California corporate income tax rate was 5.5%. The additional amount of tax due applying the worldwide combined reporting method was less than $72,000. The vote was 5–3, Justice John Paul Stevens did not participate.

The court's majority decision was written by Justice Brennan, joined by White, Marshall, Blackmun, and Rehnquist. Justice Powell wrote the dissenting opinion, joined by Burger and O'Connor. Friend-of-the-court amicus curiae briefs were filed in support of California by the Attorneys General of Idaho, Utah, Illinois, Montana, New Mexico, New York, North Dakota, Oregon, Alaska, Colorado, Connecticut, Delaware, Indiana, Kansas, Massachusetts, Michigan, Nebraska, Minnesota, Missouri, New Hampshire, North Carolina, Hawaii, and Vermont. Also, in support of California, briefs were filed by the National Governors' Association, the National Farmers Union, and the Citizens for Tax Justice.

In support of the Container Corporation, amicus briefs were filed by Allied Lyons, Coca-Cola, Colgate-Palmolive, EMI Limited, Firestone Tire & Rubber, Canadian Imperial Bank of Commerce, Caterpillar Tractor, Gulf Oil, Phillips Petroleum, Shell Oil, and Sony. Also, in support of Container, were briefs filed by the U.S. Chamber of Commerce's Committee on State Taxation, the Financial Executives Institute, the Government of the Kingdom of the Netherlands, the Confederation of British Industry, the International Bankers Association in California, and the Union of Industries of the European Union.

The Working Group agreed on three principles that should guide state taxation of the income of multinational corporations: [18]

California adopted a requirement that both United States and foreign corporations be included in a worldwide unitary group filing, absent a “water's edge” election and fee. This requirement was limited somewhat by the U.S. Supreme Court in Barclays Bank PLC v. Franchise Tax Board. The vote in that case was 7–2 in favor of California and 9–0 in the companion Colgate-Palmolive case. [19] California subsequently repealed the “water's edge” fee. Illinois requires unitary group filings for United States corporations only.

Under the unitary concept, all commonly controlled corporations within the unitary management and control group are required to join in a consolidated return filing for the state. An example of why a state would adopt unitary combined reporting is in the Statement of Intent in section 152 of Vermont's 2004 Act:

In recognition of the fact that corporate business is increasingly conducted on a national and international basis, it is the intent of the general assembly to adopt a unitary combined system of income tax reporting for corporations, and as an integral part of this proposal, to lower the corporate income tax rates. Vermont's separate accounting system is inadequate to measure accurately the income of a corporation with non-Vermont affiliates and creates tax disadvantages for Vermont corporations which compete with multistate and multinational corporations doing business in Vermont. It is the intent of the general assembly, in adopting a unitary combined reporting system, to put all corporations doing business in Vermont on an equal income tax footing, and with the revenue from the expanded and more accurate tax base, to lower Vermont's corporate income tax rates.

The enabling statute, however, excludes "overseas business organizations" from the taxable combined group so water's edge instead of worldwide combined reporting is adopted. Therefore, purely domestic businesses (i.e. national multi-state corporations) are subject to tax on 100% of their taxable profits, U.S. based multinational corporations are subject to tax on 100% of their reported U.S. profits plus foreign profits via repatriated dividends from foreign subsidiaries (if and when repatriated), and foreign based multinational corporations are subject to tax on 100% of their U.S. subsidiaries' reported U.S.profits. As a result, under water's edge combined reporting, separate accounting is only ignored for purely domestic businesses but retained for multinational corporations. Per the 2003-2004 Biennial Report of the Vermont Commissioner of Taxes, the adoption of unitary combined reporting "will diminish opportunities for certain aggressive tax management strategies that were available to multi-state corporations and will help create a level playing field with respect to Vermont-based corporations." [20]

Therefore, under water's edge, U.S. based and foreign-based multinationals have the ability to shift U.S. profits to foreign subsidiaries and avoid federal and state income taxes. Profits shifted out of the U.S. would be taxed only if and when they are repatriated as foreign dividends to a U.S. based multinational. Most foreign countries do not tax foreign dividends received by multinationals based in their countries so profits shifted out of the U.S. by U.S. subsidiaries owned by foreign based multinationals and later repatriated to the foreign parent are usually not taxed.

The State of New Hampshire adopted worldwide combined reporting in 1981 but restricted it to water's edge five years later in 1986. In 1999, in Caterpillar Inc. v. New Hampshire Department of Revenue, the court stated "We point out that the water's edge method was adopted for the benefit of foreign businesses." [21]

Approaching 30 years since the 1984 principals of the Worldwide Unitary Tax Working Group, it is questionable whether or not a competitive balance for U.S. multinationals, foreign multinationals, and purely domestic businesses has been attained. Bloomberg reporter Jesse Drucker demonstrates that separate accounting/arm's length pricing favors the multinationals in an October 2010 article titled "Google 2.4% Rate Shows How $60 Billion Lost to Loopholes" with tax strategies known as the "Double Irish" and the "Dutch Sandwich." [22] In a New York Times October 2012 Dealbook column, Victor Fleischer wrote about "Overseas Cash And The Tax Games Multinationals Play." Although billions in corporate profits are reported to be on the books of foreign subsidiaries located in tax havens, a New York Times article by David Kocieniewski titled "For U.S. Companies, Money Offshore Mean Manhattan" dated May 2013, indicates that those corporate profits are being utilized in the U.S. [23] This is supported by a more recent report by Kitty Richards and John Craig at the Center for American Progress titled "Offshore Corporate Profits - The Only Thing 'Trapped' is Tax Revenue" [24] An article by Floyd Norris in the May 23, 2013 New York Times, "The Corrosive Effect of Apple's Tax Avoidance", points out how these tax avoidance strategies will most likely be followed by many other multinational corporations. [25] And, an article by David Gelles titled "New Corporate Shelter: A Merger Abroad" dated October 8, 2013 makes a case that the best tax strategy for a U.S. based corporation is to become a foreign based corporation. [26]

The apportionment factors for state income tax are computed on a consolidated basis and applied to the income of members doing business in the state. Illinois taxes only United States corporations in this manner. California, following the Barclays case, modified its rules to include in the combined reporting only the taxable income of United States corporations. California's computation of apportionment factors is still based on worldwide group amounts unless a “water's edge” election is made.

Further reading

Related Research Articles

In taxation and accounting, transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length. The OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice. Countries with transfer pricing legislation generally follow the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in most respects, although their rules can differ on some important details.

Limited liability company US form of a private limited company

A limited liability company (LLC) is the US-specific form of a private limited company. It is a business structure that can combine the pass-through taxation of a partnership or sole proprietorship with the limited liability of a corporation. An LLC is not a corporation under state law; it is a legal form of a company that provides limited liability to its owners in many jurisdictions. LLCs are well known for the flexibility that they provide to business owners; depending on the situation, an LLC may elect to use corporate tax rules instead of being treated as a partnership, and, under certain circumstances, LLCs may be organized as not-for-profit. In certain U.S. states, businesses that provide professional services requiring a state professional license, such as legal or medical services, may not be allowed to form an LLC but may be required to form a similar entity called a professional limited liability company (PLLC).

Tax avoidance is the legal usage of the tax regime in a single territory to one's own advantage to reduce the amount of tax that is payable by means that are within the law. A tax shelter is one type of tax avoidance, and tax havens are jurisdictions that facilitate reduced taxes. Tax avoidance should not be confused with tax evasion, which is illegal.

A corporate tax, also called corporation tax or company tax, is a direct tax imposed on the income or capital of corporations or analogous legal entities. Many countries impose such taxes at the national level, and a similar tax may be imposed at state or local levels. The taxes may also be referred to as income tax or capital tax. A country's corporate tax may apply to:

Corporation tax in the Republic of Ireland Irish corporate tax regime

Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force, and created 57% of Irish OECD non-farm value-add. As of 2017, 25 of the top 50 Irish firms were U.S.–controlled businesses, representing 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. § Corporate tax inversions in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system.

Taxation in the Republic of Ireland Irish tax code

Taxation in Ireland in 2017 came from Personal Income taxes, and Consumption taxes, being VAT and Excise and Customs duties. Corporation taxes represents most of the balance, but Ireland's Corporate Tax System (CT) is a central part of Ireland's economic model. Ireland summarises its taxation policy using the OECD's Hierarchy of Taxes pyramid, which emphasises high corporate tax rates as the most harmful types of taxes where economic growth is the objective. The balance of Ireland's taxes are Property taxes and Capital taxes.

S corporation US tax term for a type of company

An S corporation, for United States federal income tax, is a closely held corporation that makes a valid election to be taxed under Subchapter S of Chapter 1 of the Internal Revenue Code. In general, S corporations do not pay any income taxes. Instead, the corporation's income and losses are divided among and passed through to its shareholders. The shareholders must then report the income or loss on their own individual income tax returns.

Income taxes in the United States are imposed by the federal government, and most states. The income taxes are determined by applying a tax rate, which may increase as income increases, to taxable income, which is the total income less allowable deductions. Income is broadly defined. Individuals and corporations are directly taxable, and estates and trusts may be taxable on undistributed income. Partnerships are not taxed, but their partners are taxed on their shares of partnership income. Residents and citizens are taxed on worldwide income, while nonresidents are taxed only on income within the jurisdiction. Several types of credits reduce tax, and some types of credits may exceed tax before credits. An alternative tax applies at the federal and some state levels.

Taxation in the Netherlands is defined by the income tax, the wage withholding tax, the value added tax and the corporate tax.

Corporate tax in the United States

Corporate tax is imposed in the United States at the federal, most state, and some local levels on the income of entities treated for tax purposes as corporations. Since January 1, 2018, the nominal federal corporate tax rate in the United States of America is a flat 21% due to the passage of the Tax Cuts and Jobs Act of 2017. State and local taxes and rules vary by jurisdiction, though many are based on federal concepts and definitions. Taxable income may differ from book income both as to timing of income and tax deductions and as to what is taxable. The corporate Alternative Minimum Tax was also eliminated by the 2017 reform, but some states have alternative taxes. Like individuals, corporations must file tax returns every year. They must make quarterly estimated tax payments. Groups of corporations controlled by the same owners may file a consolidated return.

A foreign tax credit (FTC) is generally offered by income tax systems that tax residents on worldwide income, to mitigate the potential for double taxation. The credit may also be granted in those systems taxing residents on income that may have been taxed in another jurisdiction. The credit generally applies only to taxes of a nature similar to the tax being reduced by the credit and is often limited to the amount of tax attributable to foreign source income. The limitation may be computed by country, class of income, overall, and/or another manner.

Double Irish arrangement Irish corporate tax avoidance tool

The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mostly by US multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history and by 2010 was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, changes to Irish tax law in 2010 dispensed with this requirement.

Formulary apportionment, also known as unitary taxation, is a method of allocating profit earned by a corporation or corporate group to a particular tax jurisdiction in which the corporation or group has a taxable presence. It is an alternative to separate entity accounting, under which a branch or subsidiary within the jurisdiction is accounted for as a separate entity, requiring prices for transactions with other parts of the corporation or group to be assigned according to the arm's length standard commonly used in transfer pricing. In contrast, formulary apportionment attributes the corporation's total worldwide profit to each jurisdiction, based on factors such as the proportion of sales, assets or payroll in that jurisdiction.

The Common Consolidated Corporate Tax Base (CCCTB) is a proposal for a common tax scheme for the European Union developed by the European Commission and first proposed in March 2011 that provides a single set of rules for how EU corporations calculate EU taxes, and provide the ability to consolidate EU taxes. Corporate tax rates in the EU would not be changed by the CCCTB, as EU countries would continue to have their own corporate tax rates.

Base erosion and profit shifting Multinational tax avoidance tools

Base erosion and profit shifting (BEPS) refers to corporate tax planning strategies used by multinationals to "shift" profits from higher-tax jurisdictions to lower-tax jurisdictions or no-tax locations where there is little or no economic activity, thus "eroding" the "tax-base" of the higher-tax jurisdictions using deductible payments such as interest or royalties. For the government, the tax base is a company's income or profit. Tax is levied as a percentage on this income/profit. When that income / profit is transferred to another country or tax haven, the tax base is eroded and the company does not pay taxes to the country that is generating the income. As a result, tax revenues are reduced and the government is detained. The Organization for Economic Co-operation and Development (OECD) define BEPS strategies as "exploiting gaps and mismatches in tax rules". While some of the tactics are illegal, the majority are not. Because businesses that operate across borders can utilize BEPS to obtain a competitive edge over domestic businesses, it affects the righteousness and integrity of tax systems. Furthermore, it lessens deliberate compliance, when taxpayers notice multinationals legally avoiding corporate income taxes. Because developing nations rely more heavily on corporate income tax, they are disproportionately affected by BEPS.

The Tax Attractiveness Index (T.A.X.) indicates the attractiveness of a country's tax environment and the possibilities of tax planning for companies. The T.A.X. is constructed for 100 countries worldwide starting from 2005 on. The index covers 20 equally weighted components of real-world tax systems which are relevant for corporate location decisions. The index ranges between zero and one. The more the index values approaches one, the more attractive is the tax environment of a certain country from a corporate perspective. The 100 countries include 41 European countries, 19 American countries, 6 Caribbean countries, 18 countries that are located in Africa & Middle East, and 16 countries that fall into the Asia-Pacific region.

A destination-based cash flow tax (DBCFT) is a form of border adjustment tax (BAT) that was proposed in the United States by the Republican Party in their 2016 policy paper "A Better Way — Our Vision for a Confident America", which promoted a move to the tax. It has been described by some sources as simply a form of import tariff, while others have argued that it has different consequences than those of a simple tariff.

Ireland as a tax haven Allegation that Ireland facilitates tax base erosion and profit shifting

Ireland has been labelled as a tax haven or corporate tax haven in multiple financial reports, an allegation which the state has denied in response. Ireland is on all academic "tax haven lists", including the § Leaders in tax haven research, and tax NGOs. Ireland does not meet the 1998 OECD definition of a tax haven, but no OECD member, including Switzerland, ever met this definition; only Trinidad & Tobago met it in 2017. Similarly, no EU–28 country is amongst the 64 listed in the 2017 EU tax haven blacklist and greylist. In September 2016, Brazil became the first G20 country to "blacklist" Ireland as a tax haven.

Global minimum corporate tax rate Proposed international tax scheme

The global minimum corporate tax rate, or simply the global minimum tax, is a minimum rate of tax on corporate income internationally agreed upon and accepted by individual jurisdictions. Each country would be eligible to a share of revenue generated by the tax. The aim is to reduce tax competition between countries and discourage multinational corporations (MNC) from profit shifting to achieve tax avoidance.

Repatriation tax avoidance is the legal use of a tax regime within a country in order to repatriate income earned by foreign subsidiaries to a parent corporation while avoiding taxes ordinarily owed to the parent's country on the repatriation of foreign income. Prior to the passage of the Tax Cut and Jobs Act of 2017, multinational firms based in the United States owed the U.S. government taxes on worldwide income. Companies avoided taxes on the repatriation of income earned abroad through a variety of strategies involving the use of mergers and acquisitions. Three main types of strategies emerged and were given names—the "Killer B", "Deadly D", and "Outbound F"—each of which took advantage of a different area of the Internal Revenue Code to conduct tax-exempt corporate reorganizations.

References

  1. ↑ The very complex rules are contained in 26 CFR 1.1502-1 through -100, authorized by the one paragraph 26 USC 1502.
  2. ↑ According to the CCH State Tax Handbook, 26 states either permitted or required consolidated or combined returns for 2009. See ISBN   978-0-8080-1921-3. Consolidated or combined returns are not the same as composite returns. Many states require or permit that flow through entities (partnerships, LLCs, or S corporations) file a composite return reflecting the income of nonresident members. Such composite returns are often filed in lieu of the relevant members filing separate (e.g., individual) returns.
  3. ↑ Those states requiring or permitting consolidated returns generally allow only entities joining in the Federal consolidated return to file a consolidated state return. Rules vary widely by state.
  4. ↑ For definitions, see 26 USC 1504.
  5. ↑ 26 CFR 1.1502-75 Archived 2012-10-06 at the Wayback Machine .
  6. ↑ 26 CFR 1.1502-30 Archived 2012-10-06 at the Wayback Machine and 26 CFR 1.1502-31 Archived 2012-10-06 at the Wayback Machine .
  7. ↑ 26 CFR 1.1502-12 Archived 2012-10-06 at the Wayback Machine .
  8. ↑ 26 CFR 1.1502-11 through 26 CFR 1.1502-28.
  9. ↑ 26 CFR 1.1502-13 Archived 2012-10-06 at the Wayback Machine .
  10. ↑ 26 CFR 1.1502-12 Archived 2012-10-06 at the Wayback Machine .
  11. ↑ 26 CFR 1.1502-32 Archived 2012-10-06 at the Wayback Machine .
  12. ↑ 26 CFR 1.1502-30 Archived 2012-10-06 at the Wayback Machine and 26 CFR 1.1502-31 Archived 2012-10-06 at the Wayback Machine .
  13. ↑ 26 CFR 1.1502-76 Archived 2012-10-06 at the Wayback Machine .
  14. ↑ Chorus, Jeroen M. J.; Gerverm P. H. M.; Hondius, E. H.: Introduction to Dutch Law, p. 463. ISBN   978-90-411-2507-1.
  15. ↑ United Kingdom HMRC Corporation Tax Manual CTM 80100 Group Relief.
  16. ↑ For a general discussion, with cases, see Hellerstein, Hellerstein, & Youngman, State and Local Taxation, chapter 8 section 3. ISBN   0-314-15376-4.
  17. ↑ "Container Corp. V. Franchise Tax Bd., 463 U.S. 159 (1983)".
  18. ↑ [Office of the Secretary Department of the Treasury: The Final Report of the Worldwide Unitary Taxation Working Group, Chairman's Report and Supplemental Views] (August 1984)
  19. ↑ 114 S.Ct. 2268 (1994).
  20. ↑ "Department of Taxes".
  21. ↑ "Welcome".
  22. ↑ "The Great Corporate Tax Dodge News - Bloomberg". Archived from the original on 2014-01-20. Retrieved 2014-03-25.
  23. ↑ Kocieniewski, David (22 May 2013). "For U.S. Companies, Money 'Offshore' Means Manhattan". The New York Times.
  24. ↑ "Offshore Corporate Profits: The Only Thing 'Trapped' Is Tax Revenue - Center for American Progress".
  25. ↑ Norris, Floyd (23 May 2013). "The Corrosive Effect of Apple's Tax Avoidance". The New York Times.
  26. ↑ -merger-abroad-and-a-new-home/
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