Tax Havens and CFC Rules
The cluster focuses on international corporate tax strategies, tax havens, Controlled Foreign Corporation (CFC) rules, and mechanisms like global minimum taxes to prevent multinationals from shifting profits to low-tax jurisdictions and avoiding home-country taxes.
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Not sure why this is downvoted - this is the reality in most tax laws worldwide.https://en.wikipedia.org/wiki/Controlled_foreign_corporation
You mean by not being a tax haven for profits from outside the US. Or am I missing something?
If country A undercuts taxes below a set minimum of 15%, country B is within its rights not to recognize taxes payed in A for the purpose of avoiding double taxation. As a result, country B can demand tax payments on profits generated in B regardless of what taxes were payed in A. Unfortunately, in the real world governments are beholden to the commercial interests and rarely use the mechanisms available to them. Given enough willpower offshore tax havens can be eliminated in a split-second.
Note the ‘worldwide’ here - otherwise you have capital leaving the country which decides to tax it.
Make the transaction in a country that doesn't have such a tax?
Tax any money going to these havens at a similar rate, don't allow it to be a tax deduction if the money is leaving the country.
Tax money leaving the country and have a foreign entity tax.
Double taxation treaties negate this somewhat, but there are a bunch of edge cases.
Nice twist. A country that is a tax heaven and enables a lot of business to avoid due taxes in other jurisdictions is now concerned that it can't get its own share of taxes.
Only works with the foreign revenue, US-based revenues will be taxed regardless of where they end up eventually.Europeans kinda shot themselves in the foot by not having a similar rule, and looks like they're wising up to that.