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Originally posted by: DonDiego
DonDiego fails to see how malibber's example addresses wispitfire's original question: "Is it not welfare that companies are now able to take the revenue earned here overseas to not pay taxes on it?"
[boldface added - DD]
Even if one's company is domiciled in a low-or-no-income tax country, one is required to pay US income tax on one's income earned in the US.
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A foreign corporation engaged in trade or business within the United States during the taxable year shall be taxable as provided in section 11, 55, 59A, or 1201 (a) on its taxable income which is effectively connected with the conduct of a trade or business within the United States.
***endquote
Ref: US Code, Title 26 › Subtitle A › Chapter 1 › Subchapter N › Part II › Subpart B › § 882
Originally posted by: DonDiego
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Originally posted by: malibber2Quote
Originally posted by: DonDiegoQuoteDonDiego is presently under a self-imposed restriction on stating his opinion on such matters as tax policy.
Originally posted by: wispitfire
Is it not welfare that companies are now able to take the revenue earned here overseas to not pay taxes on it?
However, he is permitted to address statements of fact. In that regard poor old DonDiego questions the proposition that domestic revenue [or, more likely "domestic profits"] of domestic corporations may be moved overseas to avoid domestic [i.e. USA] taxes.
In fact, the US tax code requires US corporations overseas to pay US income-taxes on foreign income, or at least the difference between the foreign income-tax already paid and the usually higher US income-tax, when/if that income is repatriated.
Ref: Tax Foundation
As malibber understands it here is how it works. You set up and IBC in a country that has no income tax. Typically this runs $1,200 or less and is a onetime fee. Once you have your IBC you hire a group of people to act as your board of directors typically this will run you $1,200 a year or so. The board opens a bank account for you in the name of your IBC with an international bank that does business in the host country. You redirect all of your incoming revenue to the IBC which has a 0% taxation rate and doesn't even require any accounting records. You only pay taxes when the IBC makes out a check to you personally and your bring it into the U.S. All the other money the IBC has sits there growing tax free. You can open investment accounts and do anything you would with the money you would in the U.S.
You also get ATM/ Debit Card access to your money here in the U.S. whenever you want or need it.
Then you simply wait for the next republican president to declare a tax holiday on overseas money and you bring it all back into the us tax free.
DonDiego fails to see how malibber's example addresses wispitfire's original question: "Is it not welfare that companies are now able to take the revenue earned here overseas to not pay taxes on it?"
[boldface added - DD]
Even if one's company is domiciled in a low-or-no-income tax country, one is required to pay US income tax on one's income earned in the US.
******quote***
A foreign corporation engaged in trade or business within the United States during the taxable year shall be taxable as provided in section 11, 55, 59A, or 1201 (a) on its taxable income which is effectively connected with the conduct of a trade or business within the United States.
***endquote
Ref: US Code, Title 26 › Subtitle A › Chapter 1 › Subchapter N › Part II › Subpart B › § 882
How International Corporations Avoid Some Taxes
1. Multinationals typically set up semi-independent legal entities in each country they sell.
2. Product is actually first sold internally between these subsidiaries using intercompany transactions without profit attached. (40% of accounting transactions are intercompany transactions)
3. What is attached to these intercompany transactions is an allocation of overhead which can be calculated via a variety of formulas.
4. The perfectly legal method that is used to minimize overall corporate taxes is to allocate more corporate overhead to these intercompany transactions in higher tax rate countries and less in lower tax rate countries.
5. So for example, US intercompany transactions may be burdened with 30% overhead while the Singapore Operation 15%...so when the US subsidiary sells the product to the end consumer it is carrying more cost and thus less profit to be taxed.
6. This is much different than Malibber's mentioned tax avoidance scheme of simply doing business through a foreign shell and not paying any taxes. That will method can have unpleasant consequences. The aforementioned intercompany buy-sell model does require a legal review and some international accountants, so it's not a $1200 investment.
I still think people should be allowed to sell their extra kidney to pay for any extra burdens they place on society....