Offshore profit shifting and the u.s. Tax code

STATEMENT OF SENATOR CARL LEVIN (D-MICH)
BEFORE
U.S. SENATE PERMANENT SUBCOMMITTEE ON INVESTIATIONS
ON
OFFSHORE PROFIT SHIFTING AND THE U.S. TAX CODE
September 20, 2012
America stands on the edge of a fiscal cliff. This challenge lends new urgency to a topic this
subcommittee has long investigated: how U.S. citizens and corporations have used loopholes and
gimmicks to avoid paying taxes. This subcommittee has demonstrated in hearings and
comprehensive reports how various schemes have helped shift income to offshore tax havens and
avoid U.S. taxes. The resulting loss of revenue is one significant cause of the budget deficit, and
adds to the tax burden that ordinary Americans bear.
U.S. multinational corporations benefit from the security and stability of the U.S. economy, the
productivity and expertise of U.S. workers and the strength of U.S. infrastructure to develop
enormously profitable products here in the United States. But, too often, too many of these
corporations use complex structures, dubious transactions and legal fictions to shift the profits
from those products overseas, avoiding the taxes that help support our security, stability and
productivity.
Full article: http://publicintelligence.net/hsgac-corporate-offshore-profits/
Why is this not in the news???

The complaint about off shore and over see’s movement has been in the news for years. Enough so it only need a little explaining what that statement means.

Now if I understand the chart right that is displayed MS is paying 1.2B on 3B of sells or 40% in one example and 2.8B on 9B of sales or 33.3% sounds like no advantage to move.

It also sounds like the main advantage is saving ontaxes, and that is an advantage. But the are also addvoiding one of the strenghts of this country, labor.

Just saying.

The problem with an issue like this is that it requires a technical discussion of nuances, but everyone wants to take each point and exaggerate it to some extreme.

I’ll just make one quick comment on the graph of corporate tax as a percentage of total revenue. This only measures C Corporation. S Corporations, partnerships and sole proprietors pay tax on a 1040 return. S Corporations are particularly significant because they are growing in popularity. Wikipediasays:

So as the number of S Corporations grows, the amount of income taxed on a 1040 return grows, and the percentage of income taxed on C Corporations 1120 forms shrinks. The graph does not prove that corporations are off-shoring jobs or getting tax breaks from doing so.

Oh, one more quick comment: Microsoft probably does its R&D in the US because we have an R&D credit, which reduces the taxes it pays on its US profits.

Why and how are they allowed to do so whereas we as ordinary Citizens are being prosecuted for evading taxes, are the facts in the report true and if so why is there no revolt against it, like “Boycott Wallstreet” ?

Why should a company have to pay US taxes on income not generated in the US? Whether corporations are gaming the system by moving income/assets offshore that should be claimed in the USA is an issue for the auditors to sort out.

If you live outside of the USA, you can claim the Foreign Earned Income deduction: http://www.irs.gov/Individuals/International-Taxpayers/Foreign-Earned-Income-Exclusion At 95K for 2012, more than half of US taxpayers wouldn’t pay US taxes after claiming it. Also, if you pay taxes to many foreign countries, you can also deduct that as well.

We agree it is Perfectly Legal, but does this maneuver sound like something we should continue to allow?

I believe that this way of avoiding taxes is very common, we have all the time incidents of tax fraud in Europe and even the middle class has a lot of money stashed away on Swiss, Belgian, or Lichtenstein Bank accounts and the Governments are trying to caught them but has not much luck.

I have no problem with tax planning with treaty countries (countries with whom we have a tax treaty in place so that we synchronize our taxes and share information) I have a problem when companies use non-treaty jurisdictions (AKA tax havens). The fact that some islands in the caribbean are home to so many patents on things developed here in the US is purely tax motivated.