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Repatriating Offshore Funds: 2004 Tax Windfall for Select Multinationals: Congressional Report
Carl Levin (ed)
In 2004, the Am. Jobs Creation Act (AJCA) permitted U.S. corporations to repatriate income held outside of the U.S. at an effective tax rate of 5.25% instead of the top 35% corporate income tax rate. The purpose of this tax provision was to encourage companies to return cash assets to the U.S., which proponents of the provision argued would spur increased domestic investment and U.S. jobs. In response, corporations returned $312 billion in qualified repatriation dollars to the U.S. and avoided an estimated $3.3 billion in tax payments, but the growth in American jobs and investment that was supposed to follow did not occur. The U.S. Senate has long had an investigative interest in issues involving the movement of corporate funds to offshore jurisdictions and the treatment of those funds under the U.S. tax system. Certain provisions of the U.S. tax code now encourage corporations to move jobs and money overseas. For ex., corporations may qualify for deductions and otherwise reduce their U.S. taxes for expenses that they incur to shut down U.S. plants and move their operations to other countries, and are even allowed to deduct interest on facilities they build offshore. Corporations can also defer taxes on the income of their foreign subsidiaries, generating tax savings, and use foreign tax credits to reduce their U.S. taxes. These and other tax provisions can encourage the outsourcing of American jobs. In addition, over the past ten years, some U.S. corporations with multinational operations have been reporting äóģstaggering increasesäó¯ in profits offshore, while reducing the taxes they pay to the U.S. Based on a review of the 2004 tax repatriation provision, this report describes the review and provides findings and recommendations. Figures and tables. This is a print on demand report.
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