It would alter the character of the income from CSARL from includable deemed distribution income to the U.S.
And this was the marketing company for Latin America, Canada, and the Caribbean?
But you said, ``. . . say they decide most PMs [part managers] stay in US [the United States],'' not ``move to the United States,'' ``stay i...
Caterpillar is an American success story that produces iconic industrial machines. But it is also a member of the corporate profit-shifting ...
We codified the economic substance doctrine in 2010 and we stated that the IRS can invalidate transactions that create no meaningful change ...
Tax avoidance through the use of dubious tax loopholes costs the treasury tens of billions of dollars each year, making it harder for us to ...
Is it fair to call that 'profit shifting'?
Now, Caterpillar, in its written statement submitted to the Subcommittee, says that even if it were stipulated that the changes made in 1999...
You have seen it. But you just never heard it described as a virtual one?
Profits attributable to U.S.-created intangibles should not end up in a jurisdiction without substance.
That is correct, to 'Remove . . . from the chain of title . . . for purchased . . . parts.'