text:
Corporate Tax Base Erosion and Profit Shifting (BEPS): An Examination of the Data
- Brian Blankenship
- 3 years ago
- Views:
1 Corporate Tax Base Erosion and Profit Shifting (BEPS): An Examination of the Data Mark P. Keightley Specialist in Economics Jeffrey M. Stupak Research Assistant April 30, 2015 Congressional Research Service R44013
2 Summary Congress and the Obama Administration have expressed interest in addressing multinational corporations ability to shift profits into low- and no-tax countries with little corresponding change in business operations. Several factors appear to be driving this interest. Economists have estimated that profit shifting results in significant tax revenue losses annually, implying that reducing the practice could help address deficit and debt concerns. Profit shifting and base erosion are also believed to distort the allocation of capital as investment decisions are overly influenced by taxes. Fairness concerns have also been raised. If multinational corporations can avoid or reduce their taxes, other taxpayers (including domestically focused businesses and individuals) may perceive the tax system as unfair. At the same time, policymakers are also concerned that American corporations could be unintentionally harmed if careful consideration is not given to the proper way to reduce profit shifting. Consistent with the findings of existing research, the analysis presented in this report provides indications that the magnitude of profit shifting may be significant. For example, of the $1.2 trillion in overseas profits American companies reported earning in 2012, $600 billion was attributed to seven tax havens: Bermuda, Ireland, Luxembourg, the Netherlands, Singapore, Switzerland, and the U.K. Caribbean Islands. The Netherlands was the most popular location to report profits, accounting for 14.1% of all overseas earnings of American companies. Further analysis reveals that the share of profits reported is significantly disproportional to the amount of hiring and investment made by American companies in these countries. Data on the foreign direct investment (FDI) positions of American companies are also analyzed. Examining FDI data allows for an indirect investigation into the degree of profit shifting. The FDI data show that the same seven tax haven countries accounted for nearly half (47%) of the worldwide FDI position of the United States. The data also show that an increasing share of FDI is being held via holding companies. The report discusses that some of the increased use of holding companies may be tax motivated. Lastly, data from the International Monetary Fund (IMF) and the United Nations (UN) on the location of the FDI positions of all countries indicate that profit shifting is likely an international issue. Several policy options for addressing base erosion and profit shifting are briefly discussed. Included in the discussion are the tradeoffs and considerations involved in moving closer to either a pure worldwide tax system or a pure territorial tax system. The adoption of a minimum tax or a formula apportionment system is also discussed, as well as the effects of modifying current tax policy such as broadening the definition of Subpart F income or reducing corporate tax rates. The report concludes with a discussion of the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) plan, which may have implications for American corporations even if the U.S. does not adopt the OECD s recommendations. This report is intended to assist Congress as it considers what, if any, action to take to curb profit shifting. It is one of several CRS products related to the subject of profit shifting. Where appropriate, reference is made to related CRS products that discuss the more technical issues in the international corporate tax debate. Congressional Research Service
3 Contents Introduction... 1 Overview of the U.S. International Corporate Tax System... 2 Indications of Profit Shifting by American MNCs... 4 BEA Corporate Profits by Country... 4 U.S. Foreign Direct Investment by Country... 6 U.S. Foreign Direct Investment Held Through Holding Companies... 8 Indications of Worldwide Profit Shifting Policy Options and Considerations For Reducing Profit Shifting Worldwide vs. Territorial Taxation Move Closer Toward Worldwide Taxation Move Closer Toward Territorial Taxation Does the Distinction Matter? Adopt a Minimum Tax Adopt Formula Apportionment Modify Subpart F Rules Reduce Corporate Tax Rates The OECD s BEPS Project Figures Figure 1. Share of Foreign Earned U.S. Corporate Profits in Top-10 Jurisdictions (2012)... 5 Figure 2. Employment and Property in Top-10 Profit Jurisdiction Groups as a Percentage of Foreign Employment and Investment of American MNCs (2012)... 6 Figure 3. U.S. FDI Positions as a Percentage of Total U.S FDI Positions Held Abroad, by Country (2013)... 8 Figure 4. Share of Direct Investment Position Held Through Holding Companies (2013)... 9 Figure 5. Share of Direct Investment Position Held Through Holding Companies, by Country (2013) Figure 6. Inward FDI Position in10 Largest Economies as a Percentage of GDP (IMF, 2013) Figure 7. Inward FDI Position In10 Most Popular Investment Destinations as a Percentage of GDP, Log-Scale (IMF, 2013) Figure 8. Inward FDI Position in10 Most Popular Investment Destinations as a Percentage of GDP, Log-Scale (U.N., 2013) Figure 9. Share of Total Inward FDI Position Held Through Special Purpose Entities, (2013) Tables Table 1. Ten Most Popular Places to Report Profits for U.S. Companies, Congressional Research Service
4 Appendixes Appendix A. OECD S BEPS Action Plan Status Contacts Author Contact Information Congressional Research Service
5 Introduction It has been reported with increasing frequency that American corporations are engaging in profit shifting. That is, they are using tax planning strategies to avoid, delay, or reduce their U.S. tax on income earned overseas. Included among the companies that have been mentioned are Amazon, Apple, Caterpillar, Cisco, Google, Pfizer, and Starbucks, along with a number of other well and not-so-well known businesses. 1 To curb profit shifting, some have argued for disallowing the sophisticated techniques companies use, as either part of a broader tax reform plan, or as separate legislation; presumably the separate legislation would be a stop-gap measure put in place until potential tax reform takes place. Others have argued that it is the current U.S. corporate tax rate and general approach to taxing American multinational corporations (MNCs) that is encouraging companies to shift profits and keep money abroad. The best remedy, it is argued, is to reduce the corporate rate and consider excluding most foreign earned income from taxation. This approach has also been offered as a broader tax reform package. Thus far, there is no consensus on the best way to reduce profit shifting. Profit shifting is not exclusively a U.S. problem. Foreign policymakers have also voiced concern over the tax strategies employed by U.S. corporations operating in their markets, as well as their own domestically based corporations. For example, in 2012, the Public Accounts Committee of the British House of Commons called upon executives from Amazon, Google, and Starbucks to explain their companies U.K. tax strategies. 2 German Chancellor Angela Merkel urged action to curb corporate profit shifting in a speech at the Organisation for Economic Co-operation and Development (OECD) on February 19, Similarly, French President François Hollande has called for some form of global tax harmonization. 4 In response to the growing international concern, the OECD was asked by the G20 finance ministers to develop an Action Plan on Base Erosion and Profit Shifting (BEPS). 5 The goal is to develop 15 detailed actions governments can take to reduce tax avoidance by multinational corporations (as well as individuals) worldwide. The Action Plan is scheduled to be completed in three phases: September 2014, September 2015, and December Some of the actions will require coordination and information sharing between governments, and potentially the amendment of existing tax treaties. As a result, the Action Plan relies heavily on the participation 1 For example, see Charles Duhigg and David Kocieniewski, How Apple Sidesteps Billions in Taxes, The New York Times, April 28, 2012, p. A1; Jesse Drucker, Google 2.4% Rate Shows How $60 Billion Lost to Tax Loopholes, Bloomberg, October 21, 2010, Jesse Drucker, IRS Auditing How Google Shifted Profits Offshore to Avoid Taxes, Bloomberg, October 13, 2011, and Richard Rubin, Profit Shifting: Moving to Cut U.S. Taxes, Bloomberg, February 18, 2015, BloombergQuickTake. 2 House of Commons, Committee Public Accounts, HM Revenue & Customs: Annual Report and Accounts , Nineteenth Report of Session , November 28, 2012, cmselect/cmpubacc/716/716.pdf. 3 The Federal Government of Germany, Speech by Federal Chancellor Angela Merkel to the OECD Conference, February 19, 2014, 4 France will not tolerate tax avoidance, says Francois Hollande, The Telegraph, February 6, 2014, Francois-Hollande.html. 5 For more information on the G20, see CRS Report R40977, The G-20 and International Economic Cooperation: Background and Implications for Congress, by Rebecca M. Nelson. Congressional Research Service 1
6 of all major economies. A number of G20 countries that are not part of the OECD (Argentina, Brazil, China, India, Indonesia, Russia, Saudi Arabia, and South Africa) participated in the meetings that led to the eventual adoption of the Action Plan by all G20 finance ministers. This report is intended to assist Congress as it considers what, if any, action to curb profit shifting. Data on the operation of U.S. and foreign corporations are analyzed to understand where profit may be being shifted to and to what extent. There are indications that profits are being shifted to tax-preferred or tax-haven countries, and that the amount of profits involved (and therefore the tax revenue lost) could be considerable. 6 This report discusses the methods used for shifting profits only to the extent that it is necessary for interpreting the data or discussing policy options. For a detailed discussion of the profit-shifting mechanisms used by corporations, see CRS Report R40623, Tax Havens: International Tax Avoidance and Evasion, by Jane G. Gravelle. Overview of the U.S. International Corporate Tax System The United States, in theory, taxes American corporations on their worldwide income. 7 This approach to taxation is referred to as a worldwide (or resident-based) tax system. In contrast, a territorial (or source-based) system would tax American corporations only on income earned within the physical borders of the United States. In reality, no major economy has a pure worldwide or a pure territorial tax system. 8 Although the U.S. taxes the worldwide income of American corporations, current law allows taxes to be deferred on income earned abroad until that income is repatriated (returned) to the United States. 9 Deferral is a benefit to American corporations because delayed taxes are a reduced tax expense to firms due to the time value of money. 10 In the extreme, deferral could allow an American corporation to completely avoid U.S. taxation on foreign source income if they never repatriate their overseas income, either because the income is being held abroad in financial assets or because it is permanently reinvested (e.g., in plant and equipment). The income earned by foreign branches of American corporations, however, cannot be deferred Tax haven is not a precisely defined term, but in most usages it refers to a country in many cases a small one where nonresidents can save taxes by conducting various investments, transactions, and activities. Attributes that may make a country a successful tax haven include low or nonexistent tax rates applicable to foreigners; strict bank and financial secrecy laws; and a highly developed communications, financial, and legal infrastructure. 7 The concepts discussed here are described in greater detail in CRS Report R41852, U.S. International Corporate Taxation: Basic Concepts and Policy Issues, by Mark P. Keightley and Jeffrey M. Stupak, and CRS Report RL34115, Reform of U.S. International Taxation: Alternatives, by Jane G. Gravelle. 8 For a discussion of whether the distinction between worldwide and territorial systems is still valid, see Kimberly A. Clausing, Beyond Territorial and Worldwide Systems of International Taxation, Working Paper, February 2015, at 9 Repatriation is technically accomplished via a dividend payment from a foreign subsidiary to its American parent corporation. 10 The economic concept of the time value of money states that a dollar today is more valuable than a dollar in the future. 11 A foreign subsidiary is a legal entity separate from its parent company, while a foreign branch is an extension of a domestic company. Congressional Research Service 2
7 A particular type of income which does not qualify for deferral is known as subpart F income. Named for the location in the Internal Revenue Code (IRC) where its tax treatment is defined, subpart F income generally includes passive types of income such as interest, dividends, annuities, rents, and royalties. 12 The highly fungible nature of subpart F income is such that corporations can use overseas subsidiaries to transfer taxable income from high-tax countries to low-tax countries with the ultimate goal of reducing their U.S. income tax liability. To prevent this, corporations must pay taxes on subpart F income in the year it is generated, regardless of whether it is actually repatriated to the United States. 13 A temporary exception to the subpart F income tax rules for active financing income existed for income earned between 1997 and The active financing exception relates to the income earned by American corporations that operate banking, financing, and insurance lines of business abroad. Although some of the income derived from these lines of business (e.g., interest, dividends, and annuities) could be labeled as passive, active financing income was excepted from subpart F, and thus qualified for deferral and was only taxed when it was repatriated to the United States. The exception was last extended retroactively through 2014 by P.L in the 113 th Congress, and has regularly been extended in recent years as part of tax extenders legislation. When American corporations repatriate income from subsidiaries operating abroad, that income may have already been taxed by a foreign country. If it has, corporations are generally allowed to claim a dollar-for-dollar tax credit (up to a limit) for foreign taxes paid. The credit, formally known as the foreign tax credit, is intended to alleviate the double taxation of corporate income. 14 The credit is generally limited to the amount of taxes a corporation would pay in the credit s absence, which is effectively just the U.S. corporate tax rate multiplied by the amount of income earned abroad. In other words, an American corporation may claim the foreign tax credit up to the point that reduces its U.S. tax on foreign-earned income to zero, but no further. Additionally, a separate credit must be calculated for two types of income baskets passive and non-passive income. As long as the U.S. corporate tax rate is higher than the foreign country s rate, the foreign tax credit should in principle result in the corporation owing the same amount in total taxes (U.S. plus foreign) as it would if it earned the income in the Unites States. When the foreign tax rate is higher than the U.S. tax rate, a corporation should end up paying total world taxes (U.S. plus foreign) at a tax rate higher than the U.S. rate. There are instances when a corporation could end up with excess foreign credits because of the limits that restrict the credit from reducing U.S. taxes owed below zero. Excess foreign tax credits generated in a high-tax country can potentially be used to reduce U.S. tax owed on income generated in a low-tax country via a process known as cross crediting. This is possible because deferral allows corporations to selectively decide when to repatriate income and therefore when to use excess credits. 12 Specifically, the tax treatment of subpart F income may be found in Sections 951 to 956 of the IRC. 13 A rule called check-the-box has undermined subpart F provisions by allowing foreign subsidiaries to make transactions between themselves, such as loans and royalty payments, which are not recognized as taxable transactions by law. With check-the-box a corporation can set up a foreign subsidiary that owns another foreign subsidiary. The company then checks a box on an IRS form choosing to have the lower-level subsidiary treated as a disregarded (fiscally transparent) company for tax purposes. Transactions between the two subsidiaries are then treated as if they are occurring within the same company, avoiding the subpart F anti-deferral rules. 14 Sections 901 to 909 of the IRC define the foreign tax credit rules. Congressional Research Service 3
8 Indications of Profit Shifting by American MNCs The tax returns of American corporations are private, which makes it difficult to study profit shifting directly. Several publically available datasets, however, do allow for an indirect examination into the extent that profit shifting may be occurring. The U.S. Bureau of Economic Analysis (BEA) collects data on the financial operations of American MNCs, including information on where they report profits, employ workers, make investments, conduct research and development, and carry out various other activities. The BEA also collects country-level data on the foreign direct investment (FDI) positions of U.S firms. The following sections discuss these data in turn. BEA Corporate Profits by Country American companies reported earning profits of just over $1.2 trillion abroad in 2012 according to the BEA. Table 1 shows that the 10 most popular places to report profits were responsible for approximately 65% (or $789 billion) of the total $1.2 trillion in overseas earnings. Seven of the 10 reporting jurisdictions are considered tax havens or tax-preferred countries, including the four most popular destinations: the Netherlands, Ireland, Luxembourg, and Bermuda. The other three tax-preferred countries are Switzerland, Singapore, and the U.K. Caribbean Islands. 15 Among the non-tax-preferred countries, the United Kingdom and Canada are major industrialized nations that are historically close trading partners with the United States. Norway is the biggest oil producer in Europe and the third largest exporter of natural gas in the world, which explains its placement on the list. 16 Table 1. Ten Most Popular Places to Report Profits for U.S. Companies, 2012 Rank Country Profits (millions) Profits as % of Total Overseas Profits 1 Netherlands $172, % 2 Ireland $122, % 3 Luxembourg $96, % 4 Bermuda $79, % 5 United Kingdom $74, % 6 Canada $70, % 7 Switzerland $57, % 8 Singapore $42, % 9 UK Caribbean Islands $40, % 10 Norway $32, % 15 For more information on tax havens, see CRS Report R40623, Tax Havens: International Tax Avoidance and Evasion, by Jane G. Gravelle. 16 U.S. Energy Information Administration, Norway Analysis Brief, April 28, 2014, cab.cfm?fips=no. Congressional Research Service 4
9 Rank Country Profits (millions) Profits as % of Total Overseas Profits Top 10 $789, % All Foreign Countries $1,219, % Source: CRS analysis of U.S. Bureau of Economic Analysis, Outward Activities of Multinational Enterprises: Operations of U.S. Parent Companies and Their Foreign Affiliates, Preliminary 2012 Statistics. Notes: Profits are measured as net income plus foreign taxes paid. The United Kingdom Caribbean Islands group is comprised of Cayman Islands, the British Virgin Islands, Turks and Caicos Islands, and Montserrat. The BEA does not break out data for the individual United Kingdom Caribbean Island countries. Figure 1 shows the distribution of profits reported abroad in the same 10 jurisdictions displayed in Table 1. The distribution is divided into two groups one that includes the seven tax-preferred jurisdictions and another that is comprised of the three non-tax-preferred jurisdictions. The taxpreferred jurisdictions accounted for 50% of all profits reported as being earned outside the United States, in comparison to the 15% being reported in the three non-tax-preferred jurisdictions. At first glance, the fact that the seven tax-preferred jurisdictions are responsible for a larger share of reported profits may not seem surprising a larger number of countries should account for a larger share of profits. But consider that the combined economic size of the taxpreferred group (as measured by GDP) is less than one-half that of the non-tax-preferred group ($2.23 trillion to $4.86 trillion). 17 Figure 1. Share of Foreign Earned U.S. Corporate Profits in Top-10 Jurisdictions (2012) Source: CRS analysis of U.S. Bureau of Economic Analysis, Outward Activities of Multinational Enterprises: Operations of U.S. Parent Companies and Their Foreign Affiliates, Preliminary 2012 Statistics. Notes: Profits are measured as net income plus foreign taxes paid. The tax-preferred group includes Bermuda, Ireland, Luxembourg, Netherlands, Singapore, Switzerland, and the U.K. Caribbean Islands. The non-taxpreferred group includes Canada, Norway, and the United Kingdom. 17 Data come from the United Nations Conference on Trade and Development Statistics, Congressional Research Service 5
10 Figure 2 displays the share of workers hired and the share of property, plant, and equipment owned by American companies outside of the United States in both country groups. Comparing where American firms report profits (Figure 1) with where they have a physical presence as measured by the location of their employees and tangible capital indicates a disconnect between the two. While accounting for 50% of reported profits reported worldwide, 5% of employees and 11% of property can be attributed to the tax-preferred country group. In contrast, the three nontax-preferred countries of Canada, Norway, and the United Kingdom account for 20% of employees and 29% of property held by American MNCs worldwide. Figure 2. Employment and Property in Top-10 Profit Jurisdiction Groups as a Percentage of Foreign Employment and Investment of American MNCs (2012) Source: CRS analysis of U.S. Bureau of Economic Analysis, Outward Activities of Multinational Enterprises: Operations of U.S. Parent Companies and Their Foreign Affiliates, Preliminary 2012 Statistics. Notes: Profits are measured as net income plus foreign taxes paid. The tax-preferred group includes Bermuda, Ireland, Luxembourg, Netherlands, Singapore, Switzerland, and the U.K. Caribbean Islands. The non-taxpreferred group includes Canada, Norway, and the United Kingdom. U.S. Foreign Direct Investment by Country Data on the foreign direct investment (FDI) behavior of American MNCs can also shed some light on possible profit-shifting activity. FDI generally involves a multinational corporation s investment in its foreign subsidiaries. 18 There are a number of types of investments that can be categorized as FDI and not all of them are associated with profit shifting. For example, investments in real physical capital such as production plants and equipment are counted as FDI. At the same time, FDI also captures financial flows within a company group such as reinvested earnings and intra-company loans that may or may not be supporting real capital investment. It is these financial flows that cannot be tied to corresponding real investment that economists believe may be an indication of profit shifting. 18 The other major category for international capital flows is foreign portfolio investment which mainly involves individual investment in foreign securities. Congressional Research Service 6
11 To qualify as FDI, the parent corporation must have an ownership and controlling stake in the foreign entity it is investing in. Currently, the BEA and other international statistical agencies (e.g., International Monetary Fund) require that the domestic parent hold a minimum 10% ownership interest in the foreign affiliate to categorize an investment as FDI. 19 The ownership of the foreign affiliate by the domestic parent can be either direct or indirect. An example of indirect ownership would be if the American parent established a foreign holding company which in turn owned several foreign affiliates. In this case, the American parent would still be considered to hold an FDI position in the countries where the foreign affiliates were located. Thus, FDI activity in particular countries could be indicative of funds being channeled through intermediate firms within a holding company group. Tax planning is one of the possible motivations for this corporate structure. Shown in Figure 3 are the 10 countries with the largest positions of U.S. FDI. American MNCs are reporting a significant share of their FDI as occurring in tax-preferred countries. The seven tax-preferred countries Netherlands, Luxembourg, Bermuda, Ireland, United Kingdom Caribbean Islands, Singapore, and Switzerland accounted for 47% of the FDI positions of American companies, compared to 24% for the three larger industrialized nations of the United Kingdom, Canada, and Australia. Perhaps most interesting is that the Netherlands, while only a fraction of the economic size, holds more American FDI than Australia, Canada, and the United Kingdom. 20 FDI flow data (or change in FDI over a given point of time) show similar type patterns The U.S. parent must own at least 10% of the foreign company s voting securities if it is a corporation or an equivalent interest if the foreign company is unincorporated. 20 The Dutch economy is 53% the size of Australia s, 44% the size of Canada s, and 32% the size of the U.K. s according to data from the United Nations Conference on Trade and Development Statistics, FDI position data was used because they are less susceptible to year-to-year fluctuations. Congressional Research Service 7
12 Figure 3. U.S. FDI Positions as a Percentage of Total U.S FDI Positions Held Abroad, by Country (2013) Source: CRS analysis of U.S. Bureau of Economic Analysis, U.S. Direct Investment Abroad: Balance of Payments and Direct Investment Position Data. U.S. Foreign Direct Investment Held Through Holding Companies An increasingly popular way American companies have been structuring their operations and foreign investments is through the use of holding companies. In its simplest form, a holding company is an entity established to own the securities and assets of other companies. 22 The companies under the umbrella of a holding company can be located anywhere in the world. The holding company, in turn, is owned by a U.S. parent that is then deemed to have an indirect ownership or investment interest in the jurisdiction where the holding company s subordinates are located. Figure 4 shows that over the last 30 years, the share of U.S. FDI owned through holding companies has increased from 9.4% to 46.2%. 22 Marilyn Ibarra-Caton and Raymond J. Mataloni Jr., Direct Investment Positions for 2013: Country and Industry Detail, U.S. Bureau of Economic Analysis, Washington, DC, July 2014, p. 7, 07%20July/0714_direct_investment_positions.pdf. Congressional Research Service 8
13 Figure 4. Share of Direct Investment Position Held Through Holding Companies (2013) Source: CRS analysis of U.S. Bureau of Economic Analysis, U.S. Direct Investment Abroad: Balance of Payments and Direct Investment Position Data. Holding companies offer two significant advantages. First, organizing a group of subsidiaries under the umbrella of a holding company can allow for the streamlining of management, operations, financing, and leasing agreements which can increase business efficiency, lower costs, and boost profitability. Second, holding companies present a number of tax minimization opportunities. For example, if a U.S. corporation owns its foreign subsidiaries through a foreign holding company instead of directly, it becomes possible to transfer funds from one subsidiary to another without triggering U.S. tax by using the holding company as the intermediary in the transfer. Another example involves placing valuable intellectual property (IP) with a foreign holding company located in a low-tax jurisdiction and then licensing the IP to other subsidiaries in higher-tax jurisdictions. This results in a deductible royalty payment in the high-tax jurisdictions and income in the low-tax jurisdiction. Numerous other examples exist as to how holding companies fit into the profit shifting picture For an accessible introduction to holding companies and tax strategies, see David Buss, David Hryck, and Robert Rothman, International Tax Strategies, Taxes, April Congressional Research Service 9
14 Figure 5. Share of Direct Investment Position Held Through Holding Companies, by Country (2013) Source: CRS analysis of U.S. Bureau of Economic Analysis, U.S. Direct Investment Abroad: Balance of Payments and Direct Investment Position Data. Current data limitations prevent definitively determining whether multinational companies are increasingly using the holding-company structure for non-tax business reasons or to minimize taxes. Still, it is possible to look for anomalies that may be suggestive of why holding-company use is on the rise. Shown in Figure 5 are the 10 most favored locations through which U.S. outward FDI is held via holding companies. In 2013, the amount of the U.S. FDI position abroad that was held through holding companies was approximately $2.2 trillion. Of that $2.2 trillion, 68% (or $1.5 trillion) was attributable to the seven tax-haven or tax-preferred locations of the Netherlands (27%), Luxembourg (16%), Bermuda (9%), Ireland (5%), the U.K. Caribbean Islands (5%), Singapore (4%), and Switzerland (2%). In contrast, the three traditional economies of the United Kingdom, Australia, and Germany collectively accounted for 14% of the U.S. FDI position abroad that was held through holding-company structures. Indications of Worldwide Profit Shifting Data from the International Monetary Fund (IMF) suggest that corporate profit shifting is not solely a U.S. issue. As indication of this, consider a comparison of foreign investment into the 10 largest economies and the 10 most popular investment destinations. Figure 6 displays the inward FDI positions (that is, investments in each country from the rest of the world) as a percentage of GDP for the 10 largest economies. 24 On average the 10 largest economies in the world have an inward FDI position equal to 25% of their economies. Japan has the smallest FDI position (4% of GDP), while the U.K. has the largest (63% of GDP). The United States, with the largest economy, has an inward FDI position equal to 17% of GDP. 24 More precisely, the amount of investment from other countries that the IMF measures. Congressional Research Service 10
15 Figure 6. Inward FDI Position in10 Largest Economies as a Percentage of GDP (IMF, 2013) Source: CRS Analysis of IMF, World Economic Outlook Database, April In comparison, Figure 7 shows the inward FDI positions of the 10 most popular direct investment destinations. Again, these FDI positions are the result of investment flowing in from the rest of the world. Two features of the data are immediately apparent. First, aside from Mongolia (where mining operations have attracted capital), the most popular direct investment destinations are all tax-haven or tax-preferred countries. 25 Second, the amount of investment into these countries far exceeds investment in the 10 largest economies. For example, the countries in Figure 7 have an average inward FDI position equal to 961% the size of their economies. The least popular taxpreferred country in the group, Ireland, had an FDI position equal to 156% of GDP, which is more than twice that of the United Kingdom (see Figure 6). Luxembourg had the largest FDI position (5,434% of GDP). 25 The Netherlands and Hungary do not appear on the typical tax haven lists often cited, although many argue that they should. Again, however, since the definition of what constitutes a tax haven is not universally agreed upon, these countries can arguably be placed in the tax-preferred category at a minimum. For more countries over which there is similar debate, see CRS Report R40623, Tax Havens: International Tax Avoidance and Evasion, by Jane G. Gravelle. Congressional Research Service 11
16 Figure 7. Inward FDI Position In10 Most Popular Investment Destinations as a Percentage of GDP, Log-Scale (IMF, 2013) Source: CRS Analysis of IMF, World Economic Outlook Database, April Notes: The data are graphed on a log-scale to accommodate the large range of values in a single graph. FDI data for Ireland and Malta are from 2012, as the data for 2013 were missing for these two countries. The stock of FDI in the economies displayed in Figure 7 is still notable without adjusting for countries size. The Netherlands, for example, has a larger absolute inward FDI position ($4.3 trillion) than the largest economy in the world, the United States ($2.8 trillion). Luxembourg follows close behind with a $3.3 trillion inward FDI position. Combined, the Netherlands and Luxembourg account for 27% of worldwide inward FDI positions, which is more than the two largest economies in the world the United States and China which account for 18% combined. The United Nations (U.N.) compiles data similar to the IMF. While differences in methodology, measurement issues, and countries covered by each group lead to discrepancies between the two datasets, both paint the same general picture; there is a disproportionate amount of FDI being reported in tax-haven and tax-preferred countries. Figure 8 displays the 10 countries with the highest inward FDI postion to GDP ratios as reported by the U.N. in The British Virgin Islands has the largest inward FDI position, equal to 50,513% of GDP, followed by the Cayman Islands (4,708%), Hong Kong (524%), and the Marshall Islands (503%). Congressional Research Service 12
17 Figure 8. Inward FDI Position in10 Most Popular Investment Destinations as a Percentage of GDP, Log-Scale (U.N., 2013) Source: CRS analysis of United Nations Conference on Trade and Development Statistics. Notes: The data are graphed on a log-scale to accommodate the large range of values in a single graph. GDP figure for British Virgin Islands is from A final indication that profit shifting may be occuring can be found by looking at how much investment is funneled through special purpose entities (SPEs). According to the OECD, Examples [of SPEs] are financing subsidiaries, conduits, holding companies, shell companies, shelf companies and brass-plate companies. Although there is no universal definition of SPEs, they do share a number of features. They are all legal entities that have little or no employment, or operations, or physical presence in the jurisdication in which they are created by their parent enterprises which are typically located in other jurisdictions (economies). They are often used as devices to raise capital or to hold assets and liabilities and usually do not undertake significant production. 26 Data on the use of SPEs are scarce. The OECD, however, does publish data on the inward FDI positions of the Netherlands and Luxembourg that are broken down into investment held through SPEs and non-spes. In 2013, the total inward FDI stock held via SPEs in Luxembourg and the Netherlands was $3.1 trillion and $3.9 trillion, respectively, both of which are larger than the total inward FDI stock of the United States. As Figure 9 shows, 83% ($3.2 trillion) of the inward FDI position in the Netherlands is held through SPEs. For Luxembourg the share is even higher; 96% of its inward FDI position is held through SPEs. 26 OECD, Addressing Base Erosion and Profit Shifting, 2013, p. 22, Congressional Research Service 13
18 Figure 9. Share of Total Inward FDI Position Held Through Special Purpose Entities, (2013) Source: CRS analysis of OECD Foreign Direct Investment (FDI) Statistics, FDI series from 1990 to Q Policy Options and Considerations For Reducing Profit Shifting The debate over reducing profit shifting and reforming the international tax system may involve a number of policy considerations and tradeoffs. Proposals thus far have included moving closer toward a pure-form worldwide system, moving closer toward a pure-form territorial system, adopting a new approach such as a minimum tax or formula apportionment, or modifying the current system s rules and structure. There is also on the horizon the completion of OECD s Base Erosion and Profit Shifting (BEPS) initiative. The remainder of this report discusses these considerations generally. For more detailed information see CRS Report RL34115, Reform of U.S. International Taxation: Alternatives, by Jane G. Gravelle and CRS Report R42624, Moving to a Territorial Income Tax: Options and Challenges, by Jane G. Gravelle. Worldwide vs. Territorial Taxation There have been calls for the United States to change its approach to taxing American MNCs. The United States currently follows what roughly approximates the so-called worldwide approach to taxation. While the United States generally follows this approach, corporations are typically allowed to defer paying taxes on income earned abroad until that income is brought home, or repatriated, in the form of a dividend payment to the U.S. parent. Additionally, foreign taxes paid in one country may be used to offset income earned in other countries via a process known as cross-crediting. These two features deferral and cross-crediting result in the current system straying away from the worldwide approach and into a hybrid system with both worldwide and territorial system features. Where exactly on the spectrum between worldwide and territorial taxation the current system lies is not precisely known. The general implications of moving closer toward either system are discussed below. Congressional Research Service 14
19 Move Closer Toward Worldwide Taxation If the United States were to transition toward a more pure-form worldwide system, the most straightforward way to do this would be to eliminate deferral while still allowing a credit for foreign taxes paid. Such an approach would result in U.S. investments being taxed at the same total tax rate (foreign plus U.S.), regardless of where investments were made. 27 As a result, investment decisions would be made based on real economic returns and not on any differential between U.S. and foreign tax rates. This, in turn, would lead U.S. corporations to allocate capital to its most productive use in the world economy. Additionally, corporations would largely have no incentive to shift profits or to accumulate large sums of cash overseas (like the current system incentivizes firms to do) because all earnings would be taxed currently. A reduction in the incentive to shift profits as the result of a purer-form worldwide system would also likely reduce complexity in the administration of the tax system because many tax strategies would be rendered useless. A pure-form-type system would still likely require that income and costs be allocated between domestic and foreign activities for purposes of the foreign tax credit. If the movement to a more worldwide system was accompanied by a per-country foreign tax credit limit (to eliminate cross-crediting), however, then U.S. corporations would have to allocate income and expenses between domestic and foreign activities and allocate income and expenses between affiliated foreign subsidiaries. To the extent that firms were in an excess credit position (had credits they could not use because of the foreign tax credit limit), there would be an incentive to shift profits to lower-tax countries. Without the ability to defer income, however, excess credits would likely be reduced. There are concerns over moving toward a more pure-form worldwide tax system. Without the proper safeguards in place, it is likely that a true worldwide tax system would encourage corporations to shed their U.S. corporate charter by reincorporating abroad via a process known as inversion. Several high profile U.S. companies expressed interest in inverting under the current hybrid system in early and mid In response, Treasury released a notice of regulatory changes that would further restrict the ability to invert and has indicated that additional actions are possible. Legislation was also introduced in Congress that would modify current laws meant to curb the practice, although nothing was enacted. 28 The recent regulatory changes and proposed legislative changes would likely need to be strengthened to prevent inversions under a pure worldwide system. 29 For more detailed information on corporate inversions see CRS Report R43568, Corporate Expatriation, Inversions, and Mergers: Tax Issues, by Donald J. Marples and Jane G. Gravelle. 27 To see this, consider a U.S. firm that must allocate investment between two locations. The first location, Country A, has a 15% tax rate, while the second location, Country B, has a 30% tax rate. Under a pure worldwide system, income earned in Country A would be subject to a 15% foreign tax, and then a residual 20% U.S. tax after claiming a credit for foreign taxes paid. The result is a total (foreign plus U.S.) tax of 35%. Income earned in Country B would be subject to a 20% foreign tax, and then a residual 15% U.S. tax also resulting in a total tax of 35%. Thus, under a pure worldwide system, the total tax rate in both countries is the same, and taxes have no effect on investment decisions. 28 For more information on corporate inversions, including legislative proposals, see CRS Report R43568, Corporate Expatriation, Inversions, and Mergers: Tax Issues, by Donald J. Marples and Jane G. Gravelle. 29 A detailed discussion about this subject is beyond the scope of this report and can involve intricate legal technicalities. For an introduction to this issue, see CRS Report R43568, Corporate Expatriation, Inversions, and Mergers: Tax Issues, by Donald J. Marples and Jane G. Gravelle. Congressional Research Service 15
20 Concern has also been expressed that moving from the current hybrid system to a true worldwide system would reduce America s international competitive position. Using competition as an evaluation criterion is problematic because generally it is not well defined in the context of international tax policy, and often times the competitive concepts that are used are at odds with each other. 30 For example, does increasing America s competitive position call for tax policies that promote the flow of U.S. capital (and therefore business operations and jobs) abroad to better compete in international markets? Or does it call for policies that reduce the flow of capital (and therefore business operations and jobs) abroad so that it remains in the United States and can be put to use domestically? There is an argument that these two objectives are not at odds with each other, and that promoting increased foreign investment and employment complements increased domestic investment and employment. 31 There is not conclusive evidence to support this argument. Additionally, it is important to understand that countries do not compete with each other in an economic sense. Competition implies a zero-sum game with winners and losers. But enhanced economic well-being in one country generally does not reduce economic opportunities in other countries. Instead, countries trade with each other. When countries specialize in what they have a comparative advantage at producing and trade for what they have a comparative disadvantage at producing, they are able to produce more together than in isolation. Greater production leads to more product variety, lower consumer prices, and greater average incomes. 32 For these reasons, economists typically question whether competitiveness makes sense as a tax policy objective for a country. For economists, the typical objective is economic efficiency, or the optimal allocation of limited resources. Move Closer Toward Territorial Taxation If the United States were to transition toward a more pure-form of a territorial system it would forgo taxing income earned outside its borders. This change would result in U.S. investments being taxed at the rates that exist where the investments are made. As a result, investment decisions would no longer be based solely on real economic returns, but on after-tax returns that would vary country by country. This variation, in turn, would lead U.S. corporations to allocate more investment to lower-tax countries than they otherwise would. Another feature of a territorial-based system would be that tax policy would no longer affect corporations decisions to repatriate income because there would be no tax consequence for doing so. Recall that a pure worldwide system would also remove the influence of taxes on the repatriation decision, but in that case, it would be because taxes were unavoidable and not because repatriation would be taxfree. It is argued that relative to the current hybrid system, a more territorial system would enhance the competitiveness of U.S. firms relative to their foreign competitors. Again, however, economists are typically skeptical of using competition criteria when evaluating international tax policy, whether it is comparing a territorial system with the current system or with a true worldwide 30 For a more in-depth discussion of this issue, see Jane G. Gravelle, Does the Concept of Competitiveness Have Meaning in Formulating Corporate Tax Policy? Tax Law Review, vol. 65 (2012), pp Mihir A. Desai, Fritz Foley, and James R. Hines, Domestic Effects of the Foreign Activities of US Multinationals, American Economic Journal: Economic Policy, vol. 1, no. 1 (February 2009), pp British economist David Ricardo first formalized the idea of comparative advantage in his 1817 book titled On the Principles of Political Economy and Taxation. Congressional Research Service 16
An Analysis of Where American Companies Report Profits: Indications of Profit Shifting
An Analysis of Where American Companies Report Profits: Indications of Profit Shifting Mark P. Keightley Specialist in Economics January 18, 2013 CRS Report for Congress Prepared for Members and CommitteesMore information
Tax Reform in Brazil and the U.S.
Tax Reform in Brazil and the U.S. Devon M. Bodoh Principal in Charge Latin America Markets, Tax KPMG LLP Carlos Eduardo Toro Director KPMG Brazil Agenda Overview of Global Tax Reform Overview OrganizationMore information
tax bulletin State of Play: International Tax Policy in the 111 th Congress www.venable.com AUGUST 2010 By E. Ray Beeman and Samuel Olchyk
tax bulletin www.venable.com AUGUST 2010 State of Play: International Tax Policy in the 111 th Congress By E. Ray Beeman and Samuel Olchyk The 111th Congress will soon return from its summer recess toMore information
A History of Controlled Foreign Corporations and the Foreign Tax Credit
A History of Controlled Foreign Corporations and the Foreign Tax Credit by Melissa Redmiles and Jason Wenrich A s U.S. corporations have expanded their businesses overseas in the last several decades,More information
Swiss-American Chamber of Commerce Corporate Tax Reform - Impacts on Swiss and Other European Companies
Swiss-American Chamber of Commerce Corporate Tax Reform - Impacts on Swiss and Other European Companies Marc J. Gerson Rocco V. Femia May 25-26, 2011 U.S. Tax Reform Recognized Need for Fundamental U.S.More information
U.S. DEPARTMENT OF THE TREASURY Press Center Link: http://www.treasury.gov/press-center/press-releases/pages/hp1060.aspx Statement For the Record of the Senate Committee on Finance Hearing on InternationalMore information
- 1 - The Honorable Ron Wyden Chairman Committee on Finance United States Senate 219 Dirksen Senate Office Building Washington, D.C.
The Honorable Ron Wyden Chairman Committee on Finance United States Senate 219 Dirksen Senate Office Building Washington, D.C. 20510 The Honorable Orrin Hatch Ranking Member Committee on Finance UnitedMore information
H.R. XXX Small Business Tax Relief Act of 2010
H.R. XXX Small Business Tax Relief Act of 2010 July 30, 2010 I. SMALL BUSINESS TAX RELIEF Provide small business tax relief by repealing certain information reporting requirements to corporations and toMore information
Incorporating International Tax Laws in Multinational Capital Budgeting
APPENDIX 14 Incorporating International Tax Laws in Multinational Capital Budgeting Tax laws can vary among countries in many ways, but any type of tax causes an MNC s after-tax cash flows to differ fromMore information
Taxation of Foreign Income by the U.S. and Other Governments. James R. Hines Jr. University of Michigan and UC-Berkeley February 2009
Taxation of Foreign Income by the U.S. and Other Governments James R. Hines Jr. University of Michigan and UC-Berkeley February 2009 1 American Taxation of Foreign Income. The U.S. practice of taxing foreignMore information
Tax-free. Welcome to the geography of tax avoidance. 1 Tax-free profits
Tax-free profits Welcome to the geography of tax avoidance 1 Tax-free profits International investment flows are often concentrated in countries with relatively small economies. Why? Welcome to the worldMore information
Inequality and Taxation in a Globalised World. Dr Gabriel Zucman Department of Economics, LSE Associate on the Public Economics Programme, STICERD
Department of Economics and Centre For Macroeconomics public lecture Inequality and Taxation in a Globalised World Dr Gabriel Zucman Department of Economics, LSE Associate on the Public Economics Programme,More information
Topics in the Economics of International Taxation (2): Tax Havens and Tax Holidays
Topics in the Economics of International Taxation (2): Tax Havens and Tax Holidays Center for Economic Studies Ludwig-Maximilians-Universität Munich 27 July, 2011 Dhammika Dharmapala University of IllinoisMore information
Chapter 10 FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Daniel Cassidy 1 10.1 INTRODUCTION Foreign companies with U.S. business transactions face various layers of taxation. These include income, sales,More information
Challenges of Taxing Financial Wealth
Challenges of Taxing Financial Wealth Gabriel Zucman (London School of Economics) November 2014 This talk: three points 1. The financial wealth held in offshore tax havens is large, rising, and seems largelyMore information
China s Controlled Foreign Corporation (CFC) Rules
China s Controlled Foreign Corporation (CFC) Rules Liao Tizhong: Deputy Director General of International Taxation of the State Administration of Taxation of the P. R. China In 2008, China launched a majorMore information
A Comparison of Key Aspects of the International Tax Systems of Major OECD and Developing Countries. Prepared for. Business Roundtable
A Comparison of Key Aspects of the International Tax Systems of Major OECD and Developing Countries Prepared for Business Roundtable May 10, 2010 This document has been prepared pursuant to an engagementMore information
Tax Haven Legislation: Debunking the Myths
Spring Audit Session / Income Tax Conference Memphis, TN April 21, 2015 Tax Haven Legislation: Debunking the Myths Charles Fischer Sr. Manager, National Multistate Tax Services Deloitte Tax LLP firstname.lastname@example.com information
OECD BEPS Project - Impact on UK tax law. Munich, 21 April 2016
OECD BEPS Project - Impact on UK tax law Munich, 21 April 2016 Slide 3 5 Recent tax developments in the UK 6-8 Action 2 - Hybrid mismatch arrangements 9 10 Action 3 - CFC Rules 11 12 Action 4 - InterestMore information
Congress Should End Deferral Rather than Adopt a Territorial Tax System. Understanding the Debate Over the U.S. International Corporate Tax Rules
CTJ Citizens for Tax Justice March 23, 2011 Contact: Bob McIntyre (202) 299-1066 x22 Steve Wamhoff (202) 299-1066 x33 Congress Should End Deferral Rather than Adopt a Territorial Tax System UnderstandingMore information
Eliminating Double Taxation through Corporate Integration
FISCAL FACT Feb. 2015 No. 453 Eliminating Double Taxation through Corporate Integration By Kyle Pomerleau Economist Key Findings The United States tax code places a double-tax on corporate income withMore information
Cash Versus Accrual Accounting: Tax Policy Considerations
Cash Versus Accrual Accounting: Tax Policy Considerations Raj Gnanarajah Analyst in Financial Economics Mark P. Keightley Specialist in Economics April 24, 2015 Congressional Research Service 7-5700 www.crs.govMore information
Tax and Tax Incentive Effects on Investment and Policy Implications: ~ How does MNE tax planning factor in?
Organisation for Economic Co-operation and Development Tax and Tax Incentive Effects on Investment and Policy Implications: ~ How does MNE tax planning factor in? Workshop on Investment Incentives JointMore information
Are U.S. Effective Corporate Tax Rates Low? Technology CEO Council
Are U.S. Effective Corporate Tax Rates Low? Prepared for: Technology CEO Council February 1, 2010 National Economic Consulting This document has been prepared pursuant to an engagement between PricewaterhouseCoopersMore information
Allow me to point out ten ways this can be done.
How Developing Countries can take Control of their own Tax Destinies By Krishen Mehta* July, 2014 Introduction: The question of how developing countries get a fair deal on tax justice is an important andMore information
2015 Proposed Draft Provisions to US Model Income Tax Treaty: Impact on Innovation, Licensing and Digital Economy
2015 Proposed Draft Provisions to US Model Income Tax Treaty: Impact on Innovation, Licensing and Digital Economy 2015 Bierce & Kenerson, P.C. All rights reserved. Digital mobility is driving a rapidlyMore information
How do companies avoid tax?
How do companies avoid tax? Tax avoidance techniques for multinational companies are all about location. They consist of where a company chooses to open offices and create subsidiaries, and where it choosesMore information
THE ADVANCED DIPLOMA IN INTERNATIONAL TAXATION June 2008 PAPER IIA UNITED KINGDOM OPTION ADVANCED INTERNATIONAL TAXATION TIME ALLOWED 3¼ HOURS You should answer FOUR out of the seven questions. Each questionMore information
Avoiding U.S. Investment Tax Traps
Avoiding U.S. Investment Tax Traps Structuring Real Estate and Other Fund Investments Presented by: Joseph Gulant and Daniel Blickman Major Categories of Tax to Consider in Planning International TransactionsMore information
Multinationals will be concerned about additional complexity in controlled foreign company proposals
Multinationals will be concerned about additional complexity in controlled foreign company proposals 7 April 2015 In brief Multinational enterprises (MNEs) will be concerned about the Base Erosion andMore information
United States General Accounting Office. Testimony Before the Committee on Finance, United States Senate
GAO United States General Accounting Office Testimony Before the Committee on Finance, United States Senate For Release on Delivery Expected at 10:00 a.m. EST on Thursday March 8, 2001 ALTERNATIVE MINIMUMMore information
TAX ISSUES RAISED BY LNG PROJECTS Jon Lobb Baker Botts L.L.P. ABSTRACT This paper discusses tax issues that may be encountered by a company investing in an LNG project. 1. Income Taxes A seller's incomeMore information
Moving to Territoriality? Implications for the United States and the Rest of the World
WP/06/161 Moving to Territoriality? Implications for the United States and the Rest of the World Peter Mullins 2006 International Monetary Fund WP/06/161 IMF Working Paper Fiscal Affairs Department MovingMore information
Recent developments regarding Mexico s tax treaty network and relevant court precedents
Recent developments regarding Mexico s tax treaty network and relevant court precedents Mexico has a relatively short background on the negotiation and application of treaties for the avoidance of doubleMore information
Credit vs. Exemption: A Comparative Study of Double Tax Relief in the United States and Japan
Credit vs. Exemption: A Comparative Study of Double Tax Relief in the United States and Japan Lawrence Lokken * and Yoshimi Kitamura ** The overriding issue in international taxation is the problem ofMore information
Tax Reform: An Overview of Proposals in the 112 th Congress
Tax Reform: An Overview of Proposals in the 112 th Congress James M. Bickley Specialist in Public Finance January 14, 2011 Congressional Research Service CRS Report for Congress Prepared for Members andMore information
Taxand Asia Senior School CONTROLLED FOREIGN COMPANIES
Taxand Asia Senior School CONTROLLED FOREIGN COMPANIES OUTLINE Controlled Foreign Company ( CFC ) - the concept CFC The international scenario A comparative with other jurisdictions CFC and the IndianMore information
Spain Tax Alert. Corporate tax reform enacted. Tax rate. Tax-deductible expenses. International Tax. 2 December 2014
International Tax Spain Tax Alert 2 December 2014 Corporate tax reform enacted Contacts Brian Leonard email@example.com Francisco Martin Barrios email@example.com Elena Blanque firstname.lastname@example.com information
EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES DENNIS S. FERNANDEZ INNA S. SHESTUL Fernandez & Associates, L.L.P. Fernandez & Associates, L.L.P. 1047 El Camino Real, SteMore information
National Tax Journal, June 2012, 65 (2), 247 282 FOREIGN TAXES AND THE GROWING SHARE OF U.S. MULTINATIONAL COMPANY INCOME ABROAD: PROFITS, NOT SALES, ARE BEING GLOBALIZED Harry Grubert The foreign shareMore information
The OECD nations have split virtually evenly over the best
Forum on Moving Towards a Territorial Tax System Structuring an Exemption System for Foreign Income of U.S. Corporations Abstract - About half the OECD countries provide a tax credit for foreign taxesMore information
U.S. Taxation of Foreign Investors
PART OF THE LEHMAN TAX LAW KNOWLEDGE BASE SERIES United States Taxation Of Investors U.S. Taxation of Foreign Investors Non Resident Alien Individuals & Foreign Corporations By Richard S. Lehman Esq. TAXMore information
International investment continues to struggle
FDI IN FIGURES December 2014 International investment continues to struggle Figures for the first half of 2014 point to stalled FDI flows Findings FDI fell in the first quarter of 2014 before reboundingMore information
Tom Neubig, Robert Carroll and Gerald Prante. Quantitative Economics & Statistics (QUEST) Ernst & Young Center for Tax Policy Ernst & Young LLP
April 2011 Tax Insights Ernst & Young LLP s analysis of four hypothetical companies shows Wyden-Coats tax reform plan would lower tax burden for more companies than Deficit Commission plan Tom Neubig,More information
THE TAX BURDEN ON CROSS-BORDER INVESTMENT: COMPANY STRATEGIES AND COUNTRY RESPONSES HARRY GRUBERT CESIFO WORKING PAPER NO. 964 CATEGORY 1: PUBLIC FINANCE JUNE 2003 PRESENTED AT CESIFO CONFERENCE ON MEASURINGMore information
How Much Do U.S. Multinational Corporations Pay in Foreign Income Taxes?
FISCAL FACT May. 2014 No. 432 How Much Do U.S. Multinational Corporations Pay in Foreign Income Taxes? By Kyle Pomerleau Economist Key Findings The United States worldwide system of corporate taxationMore information
SPECIAL REPORT. The Importance of Tax Deferral and A Lower Corporate Tax Rate
February 2010 No. 174 The Importance of Tax Deferral and A Lower Corporate Tax Rate By Robert Carroll Senior Fellow Tax Foundation Introduction The Congress and Administration decided to postpone actionMore information
TAX LAWS AMENDMENT (TAX INTEGRITY MULTINATIONAL ANTI-AVOIDANCE LAW) BILL 2015 EXPOSURE DRAFT EXPLANATORY MATERIAL Table of contents Glossary... 1 Tax integrity multinational anti-avoidance law... 3 GlossaryMore information
Coming to America. U.S. Tax Planning for Foreign-Owned U.S. Operations
Coming to America U.S. Tax Planning for Foreign-Owned U.S. Operations September 2015 Table of Contents Introduction... 2 Tax Checklist for Foreign-Owned U.S. Operations... 2 Typical Life Cycle of Foreign-OwnedMore information
The 3.8% Medicare Contribution Tax on Unearned Income, Including Real Estate Transactions
The 3.8% Medicare Contribution Tax on Unearned Income, Including Real Estate Transactions Mark P. Keightley Analyst in Public Finance October 7, 2010 Congressional Research Service CRS Rept f CongressMore information
Australia s position in global and bilateral foreign direct investment
Australia s position in global and bilateral foreign direct investment At the end of 213, Australia was the destination for US$592 billion of global inwards foreign direct investment (FDI), representingMore information
EXTERNAL DEBT AND LIABILITIES OF INDUSTRIAL COUNTRIES. Mark Rider. Research Discussion Paper 9405. November 1994. Economic Research Department
EXTERNAL DEBT AND LIABILITIES OF INDUSTRIAL COUNTRIES Mark Rider Research Discussion Paper 9405 November 1994 Economic Research Department Reserve Bank of Australia I would like to thank Sally BanguisMore information
Legal Alert: FY 2016 Budget Tax Proposals Target Insurance Companies
Tax Proposals Target February 3, 2015 On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would imposeMore information
FDI IN FIGURES. April 2013
97 98 99 1 2 3 4 5 6 7 8 9 1 11 12 97 98 99 1 2 3 4 5 6 7 8 9 1 11 12 p p FDI IN FIGURES April 213 According to preliminary estimates, global FDI flows have declined in 212 by 14% from 211 to USD 1.4 trillionMore information
Chapter URL: http://www.nber.org/chapters/c7726
This PDF is a selection from an out-of-print volume from the National Bureau of Economic Research Volume Title: Taxing Multinational Corporations Volume Author/Editor: Martin Feldstein, James R. HinesMore information
In 2012, GNP in constant prices increased by 1.8% compared with 2011.
8 Economy In 2012, GNP in constant prices increased by 1.8% compared with 2011. The building and construction sector fell by 7.7% in value added terms in 2012 compared to 2011. Manufacturing industry decreasedMore information
Top 5 TAX ChAllenges And strategies. www.cliftoncpa.com www.vantagepointglobaltax.com
Top 5 TAX ChAllenges And strategies for multinational CompAnies www.cliftoncpa.com www.vantagepointglobaltax.com VantagePoint is a product of U.S. Tax Advantage, an affiliate of Clifton Gunderson. TABleMore information
S CORP vs. C CORP vs. LLC: WHICH IS RIGHT FOR YOUR BUSINESS?
S CORP vs. C CORP vs. LLC: WHICH IS RIGHT FOR YOUR BUSINESS? One of the significant decisions you face when starting a company is deciding through which type of legal entity you will operate the business.More information
Multinational firms, intellectual property and taxation
Multinational firms, intellectual property and taxation Rachel Griffith and Helen Miller Institute for Fiscal Studies 10 October 2013 Griffith and Miller (IFS) Multinational firms 10 October 2013 1 / 29More information
May 20, 2009 Client Alert
Client Alert Bei j i n g Fr a n k f u r t Ho n g Ko n g Lo n d o n Lo s An g e l e s Mu n i c h Ne w Yo r k Si n g a p o r e To k y o Wa s h i n g t o n, DC International Tax Regime Targeted in LatestMore information
Belgium in international tax planning
Belgium in international tax planning Presented by Bernard Peeters and Mieke Van Zandweghe, tax division at Tiberghien Belgium has improved its tax climate considerably in recent years. This may be illustratedMore information
Delivering U.S. International Tax Advice to U.S. Clients Doing Business Abroad
Delivering U.S. International Tax Advice to U.S. Clients Doing Business Abroad OGLE INTERNATIONAL TAX ADVISORS www.ogleintltax.com OUR INTERNATIONAL TAX PRACTICE INCLUDES BOTH CPAS AND ATTORNEYS WITH BIGMore information
INTERNATIONAL TAX COMPLIANCE FOR GOVERNMENT CONTRACTORS Mark T. Gossart Alison N. Dougherty September 26, 2012 2012 All Rights Reserved 805 King Farm Boulevard Suite 300 Rockville, Maryland 20850 301.231.6200More information
Insights on... WEALTH PLANNING CORPORATE TAX INVERSIONS Trends and Consequences Suzanne Shier Wealth Planning Practice Executive and Chief Tax Strategist July 31, 2014 Corporate tax inversions continueMore information
Buying and Selling: Cross-border mergers and acquisitions and the US corporate income tax
Buying and Selling: Cross-border mergers and acquisitions and the US corporate income tax Prepared for the Business Roundtable March 2015 Buying and Selling: Cross-border mergers and acquisitions and theMore information
COMBINED REPORTING WITH THE CORPORATE INCOME TAX Issues for State Legislatures William F. Fox and LeAnn Luna * November, 2010 Report commissioned by the NCSL Task Force on State & Local Taxation of CommunicationsMore information
OECD Tax Alert. BEPS action 2: Neutralizing the effects of hybrid mismatch arrangements. OECD proposals. International Tax. 16 October 2015.
International Tax OECD Tax Alert Contacts Bill Dodwell email@example.com Joanne Bentley firstname.lastname@example.com Joanne Pleasant firstname.lastname@example.com Simon Cooper email@example.com DavidMore information
International Taxation Overview of Key Concepts for Tech Companies
International Taxation Overview of Key Concepts for Tech Companies SJSU High Tech Tax Institute Academy October 21, 2011 William R. Skinner, Esq. email@example.com Fenwick & West LLP Silicon ValleyMore information
Evolution of Territorial Tax Systems in the OECD
www.pwc.com/us/nes Evolution of Territorial Tax Systems in the OECD Evolution of Territorial Tax Systems in the OECD April 2, 203 Prepared for The Technology CEO Council Evolution of Territorial Tax SystemsMore information
Tax considerations for Pharmaceutical & Life Sciences Industry 27 November 2013 27 November 2013
www.pwc.com/sg Tax considerations for Pharmaceutical & Life Sciences Industry 27 November 2013 27 November 2013 Discussion points 1. Update on few key tax, TP and GST points from Singapore perspectiveMore information
Selected Recently Expired Business Tax Provisions ( Tax Extenders )
Selected Recently Expired Business Tax Provisions ( Tax Extenders ) Jane G. Gravelle Senior Specialist in Economic Policy Donald J. Marples Specialist in Public Finance Molly F. Sherlock Coordinator ofMore information
News Flash Hong Kong Tax. November 2015 Issue 10. In brief. In detail. www.pwchk.com
News Flash Hong Kong Tax Understanding the IRD s views on emerging corporate tax issues, in particular the practice on processing Hong Kong tax resident certificate applications November 2015 Issue 10More information
Railroad Retirement Board: Trust Fund Investment Practices
Railroad Retirement Board: Trust Fund Investment Practices Scott D. Szymendera Analyst in Disability Policy March 15, 2016 Congressional Research Service 7-5700 www.crs.gov RS22782 Summary Beginning inMore information
Global Effective Tax Rates
www.pwc.com/us/nes Global s Global s April 14, 2011 This document has been prepared pursuant to an engagement between PwC and its Client. As to all other parties, it is for general information purposesMore information
Greece Country Profile
Greece Country Profile EU Tax Centre March 2013 Key factors for efficient cross-border tax planning involving Greece EU Member State Double Tax Treaties With: Albania Estonia Lithuania Serbia Armenia FinlandMore information
ACHIEVABLE CORPORATE TAX REFORM 2013 PETERSON INSTITUTE FOR INTERNATIONAL ECONOMICS DECEMBER 12, 2012 Gary Clyde Hufbauer, Reginald Jones Senior Fellow Martín Vieiro, Research Analyst Realistic Goals forMore information
EXECUTIVE OFFICE OF THE PRESIDENT COUNCIL OF ECONOMIC ADVISERS U.S. INBOUND FOREIGN DIRECT INVESTMENT JUNE 211 EXECUTIVE SUMMARY The United States welcomes the investment and the jobs supported by theMore information
Debt and equity finance and interest allocation rules
Debt and equity finance and interest allocation rules Background paper for Session 4 of the Victoria University of Wellington Tax Working Group October 2009 Prepared by the Policy Advice Division of theMore information
Budget 2016 CHANGES IN DUTCH TAXATION FOR 2016. www.fi sconti.com
Budget 2016 CHANGES IN DUTCH TAXATION FOR 2016 www.fi sconti.com Table of contents Changes in Dutch payroll and income tax Tax credits and rates in 2016 ----------- 3 Emigration of substantial interestMore information
International Investment. Australia. Economic Diplomacy, Trade Advocacy and Statistics Section Department of Foreign Affairs and Trade September 2015
International Investment Australia 214 International Investment Australia 214 Economic Diplomacy, Trade Advocacy and Statistics Section Department of Foreign Affairs and Trade September 215 ISSN 223-6571More information
FIXING THE SYSTEM: AN ANALYSIS OF ALTERNATIVE PROPOSALS FOR THE REFORM OF INTERNATIONAL TAX. Harry Grubert and Rosanne Altshuler
National Tax Journal, September 2013,66 (3), 671-712 FIXING THE SYSTEM: AN ANALYSIS OF ALTERNATIVE PROPOSALS FOR THE REFORM OF INTERNATIONAL TAX Harry Grubert and Rosanne Altshuler We evaluate proposalsMore information
Foreign or Domestic Tax Havens: The Location Decision for Intangible Property by U.S. Firms
Foreign or Domestic Tax Havens: The Location Decision for Intangible Property by U.S. Firms Bradley P. Lindsey North Carolina State University Wendy M. Wilson* Texas Christian University May 2015 * CorrespondingMore information
DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE PROTOCOL BETWEEN THE UNITED STATES OF AMERICA AND THE FRENCH REPUBLIC SIGNED AT WASHINGTON ON DECEMBER 8, 2004 AMENDING THE CONVENTION BETWEEN THEMore information
Statement of the U.S. Chamber of Commerce
Statement of the U.S. Chamber of Commerce ON: TO: Hearing on Tax Reform and the U.S. Manufacturing Sector House Committee on Ways and Means DATE: July 19, 2012 The Chamber s mission is to advance humanMore information
US Protocol amending the Australia-USA double taxation convention
US Protocol amending the Australia-USA double taxation convention 1. Specification of policy objective The key objective in updating Australia s tax treaty with the United States is to make a significantMore information
U.S. Foreign Tax Credit An Overview
U.S. Foreign Tax Credit An Overview KEY ISSUES IN US TAXATION ON UNREPATRIATED EARNINGS MAJOR FACTORS WHICH EFFECT CALCULATION - Foreign Earnings and Foreign Taxes Based on US tax concepts e.g. E&P, definitionMore information
United States Corporate Income Tax Summary
United States Corporate Income Tax Summary SECTION 1: AT A GLANCE CliftonLarsonAllen LLP 222 Main Street, PO Box 1347 Racine, WI 53401 262-637-9351 fax 262-637-0734 www.cliftonlarsonallen.com CorporateMore information
Hong Kong s Double Tax Treaty Network
TAX FLASH July 2010 TAX FLASH July 2010 Hong Kong s Double Tax Treaty Network To remain as an international financial and commercial centre, it has become important for Hong Kong to promote its transparencyMore information
Spain Tax Alert. Broad-based corporate tax reform proposed. Tax rate. Tax-deductible expenses. International Tax. 2 July 2014
International Tax Spain Tax Alert 2 July 2014 Broad-based corporate tax reform proposed Contacts Brian Leonard firstname.lastname@example.com Francisco Martin Barrios email@example.com Elena Blanque firstname.lastname@example.com information
United States Tax Alert
International Tax United States Tax Alert Contacts Jeff O Donnell firstname.lastname@example.com Paul Crispino firstname.lastname@example.com Jason Robertson email@example.com April 6, 2016 Anti-Inversion Guidance:More information
www.pwc.com U.S. Legislative Outlook Tom Patten 2 March 2011
www.pwc.com U.S. Legislative Outlook Tom Patten 2 Agenda Understanding the U.S. legislative process. Recent legislative developments. Proposals. 2 Understanding the U.S. Legislative Process The Long RoadMore information
Your partner. in Hong Kong
Your partner in Hong Kong About our firm Midland Consult (Hong Kong) Limited, was set up in 2009 and it s a subsidiary which forms a part of Midland Group of companies a highly skilled professional corporateMore information
Instructions for Form 1116
2005 Instructions for Form 1116 Foreign Tax Credit (Individual, Estate, or Trust) Section references are to the Internal Revenue Code unless otherwise noted. Department of the Treasury Internal RevenueMore information
CORPORATE INCOME TAX. Effective Tax Rates Can Differ Significantly from the Statutory Rate. Report to Congressional Requesters
United States Government Accountability Office Report to Congressional Requesters May 2013 CORPORATE INCOME TAX Effective Tax Rates Can Differ Significantly from the Statutory Rate GAO-13-520 May 2013More information
Nordea Asset Management. Responsible corporate tax practices
Nordea Asset Management Responsible corporate tax practices Photo: istockphoto Graphic design: Lina Johansson. Sense Design March 2014 Responsible corporate tax practices Thematic Report. Nordea AssetMore information
Tax Provisions in Administration s FY 2016 Budget Proposals
Tax Provisions in Administration s FY 2016 Budget Proposals Insurance February 2015 kpmg.com HIGHLIGHTS OF INSURANCE TAX PROPOSALS IN THE ADMINISTRATION S FISCAL YEAR 2016 BUDGET KPMG has prepared a 111-pageMore information
Is there a Race to the Bottom in Corporate Taxes? An Overview of Recent Research. By Mike Devereux, Ben Lockwood and Michela Redoano
Is there a Race to the Bottom in Corporate Taxes? An Overview of Recent Research By Mike Devereux, Ben Lockwood and Michela Redoano Statutory rates of corporation tax in developed countries have fallenMore information
Malta launches patents exemption
Malta launches patents exemption Background The Maltese government published regulations for the application of an exemption from corporate tax on royalties (and similar income) derived from qualifyingMore information
Japan s Foreign Subsidiaries Dividends Exclusion
Proceedings from the 2009 Sho Sato Conference on Tax Law, Social Policy, and the Economy Japan s Foreign Subsidiaries Dividends Exclusion Toshio Miyatake Adachi, Henderson, Miyatake & Fujita All rightsMore information
Instructions for Form 1116 Foreign Tax Credit (Individual, Estate, or Trust)
2009 Instructions for Form 1116 Foreign Tax Credit (Individual, Estate, or Trust) Department of the Treasury Internal Revenue Service Section references are to the Internal K-1 (Form 1041), Schedule K-1More information


text:
Create a Ning Network!
Well my name is Danny. I actully live in Rocklin. But just really want to get back into playing some competive tennis. Maybe we can get more people to join this and hook up. I have a court at my apartments in rocklin by Sierra College. We could do practice sessions I have a ball hopper and all that stuff. Well Anyways. Give me a call! 510-393-4583. (Its my company phone based out of the Bay.) But…
© 2018 Created by Mark / The Mayor.
Powered by
Badges |
Report an Issue |
Terms of Service
Please check your browser settings or contact your system administrator.

subset: commoncrawl


text:
December Tour
The December 2018 Key West Home Tours™ will be held December 28-29 from 3:00 PM to 6:00 PM. CLICK HERE FOR DETAILS This year we are offing a season ticket …
Welcome to our 2018-2019 season!Get Tickets Tour Information
The annual Key West Home Tours™ are one of the oldest and longest running home tours in America, with the first tour in 1960. Old Island Restoration Foundation (OIRF) conducts the tours and they are funded in part by our generous supporters. Each tour features five lovely homes and gardens reflecting the varied tastes and originality of their owners. This year we're featuring a Bonus 6th Stop at historic inns/hotels that will feature free drinks and nibbles.
You will be enchanted by exquisite restorations, creative renovations and delightful interiors featuring art collections, antiques, and much more. All proceeds from the tours stay in our local community fulfilling OIRF's mission of "Celebrating and sustaining Key West's unique architecture, culture and history." Grants are provided to local home owners and non-profits to fix up their buildings in the historic district, scholarships are provided to Key West High School students and funds are used to maintain Key West Oldest House Museum and Garden.
All members of Old Island Restoration Foundation Receive FREE Key West Home Tours tickets! For nearly 60 years OIRF has been putting on the tours to raise money to protect Key West's Historic District, maintain the Oldest House Museum, provide grants to non-profits who need to fix up their historic properties and to provide scholarships to Key West High School students. Join today and help the cause!
Nominate a Key West home for future OIRF Home Tours by contacting OIRF Administrator Chris Hamilton, 305.294.9501 or email at firstname.lastname@example.com
Become a 59th Annual 2018-2019 Key West Home Tours Sponsor
Click here on our Home Tour Archive to view information about our past Home Tours from 1960 onward to today.
A winner for this year's Home Tours Poster Contest was revealed at the 59th Annual 2018-2019 Season Kickoff Party, on Thursday, November 15. Pictures of the event on our page here.
The December 2018 Key West Home Tours™ will be held December 28-29 from 3:00 PM to 6:00 PM. CLICK HERE FOR DETAILS This year we are offing a season ticket …


text:
We're honored to be your local San Diego promotional partner. As such, we understand the importance of using American Made promotional products. For some of our clients, "Made in the U.S.A." is a must.
At EmbroidMe San Diego, we have a variety of promotional products and apparel manufactured right here in the U.S. Made with quality materials and superior craftsmanship, you'll be proud to have these products represent your brand.
If American Made products are important to you and your customers, be sure to let us know. We'll be delighted to give you some ideas and inspiration. Feel free to contact us or stop by our showroom in Kearny Mesa for more ideas!


text:
Tagged With: triathlons
Specialized Concept Store Opens in Quezon City
Specialized Philippines is among the pioneers of changing the face of bike shops in the country with the opening of their first concept store in 2013. With the growth in the cycling industry, they are reaching more territories with the opening of their concept store in Quezon City located at 11 Congressional Avenue Extension, Barangay … Continue reading
Weapon of Choice: Suunto Ambit 2S
Read about: "My Runs" is Now Powered by Suunto and All About Suunto You start to run for fun and the next thing you know you've caught the running bug and then you evolve to the longer runs or evolve into a multisports athlete. One of the key things you'll need is how to measure … Continue reading
Now Available: Fuel Belt Ironman Series
Hydration and race nutrition is very important in a race especially for long races and multisports. In a race, you sweat and let go of the nutrients in the body and chances are if you don't replace them muscle pains, fatigue or even injury can happen. I go over the race course every race on … Continue reading


text: Select an international website Zoover.at Zoover.be Zoover.ch Zoover.com Zoover.com.tr Zoover.com.ua Zoover.cz Zoover.de Zoover.dk Zoover.es Zoover.fr Zoover.gr Zoover.hu Zoover.it Zoover.lt Zoover.nl Zoover.no Zoover.pl Zoover.pt Zoover.ro Zoover.ru Zoover.se Home Destinations Accommodations Add review Add review Add photos Add videos Add new accommodation Add attraction Home Add review Netherlands Groningen Ten Boer Accommodations Ten Boer Reviews (0) Photos & videos (10) Accommodations (2) Attractions (158) Weather forecast Map Tips (0) More Question and Answer (0) Appreciation 7.0 Culture 6.0 Surroundings 7.0 Atmosphere 7.0 Care for nature 8.0 Weather -2° / 2° 14 Dec 2018 Weather forecast and climate... 7 1 Review Are you looking for a well-reviewed accommodation for your holiday in Ten Boer? Below you can find all accommodations in Ten Boer. Find the best deals Most visitors found the best deal for Ten Boer with: 1 Booking.com Check price TOP More suppliers Collapse Sort by Zoover recommends Rating Reviews Distance from centre 2 Accommodations Netherlands, Groningen, Ten Boer Location Radius: Select 2 km 10 km 20 km 50 km Country Netherlands Region Groningen Destination Ten Boer Accommodation Accommodation Hotels in Ten Boer Country house in Ten Boer Accommodation star count 3 Facilities Room service Snack bar / cafeteria Restaurant More facilities User Rating Scores well regarding Appreciation Location Service Value for money Food Rooms Interior Space More criteria Search within results: 9.7 click Add review Hotel: De Pleisterplaats *** Ten Boer, 0.5 km from center Netherlands Groningen Ten Boer 9 click Add review Country house: Boerderij Blokzijl Ten Boer, 0.1 km from center Netherlands Groningen Ten Boer Hotels Hotels in Groningen Hotels in Delfzijl Information about Ten Boer Weather Ten Boer Map Ten Boer Photos Ten Boer Videos Ten Boer Question and Answer Ten Boer Destinations nearby Harkstede Westerbroek Scharmer Westeremden Overschild Garmerwolde Ten Post Are you looking for a well-reviewed accommodation for your holiday in Ten Boer? Below you can find all accommodations in Ten Boer. Ten Boer scores a 7.0 out of 10, based on 1 reviews read more Are you looking for a good reviewed accommodation for your holiday in Ten Boer? Below you can find all accommodations in Ten Boer. You can find comments regarding 1 Hotel and 1 Country house in Ten Boer. Please use the filters on the left to find your ideal accommodation. Furthermore you can find 10 holiday photos regarding Ten Boer on the Zoover website. - - - Less text


text:
Featured post
Buy All Quiet on the Home Front here.
All Quiet on the Home Front is almost sold out. You can buy the last copies here. It is also available now at the wonderful Tipi Book...
Tuesday, 6 January 2009
George Georgiou again
Last month, I had the pleasure to talk with George Georgiou for a story in this week's BJP. Like Jeffrey Silverthorne, Georgiou also touches on going beyond the familiar, something that has relevance both for his Turkish work and his images from public transport in the UK and Ukraine. Georgiou photographed from trams and buses in the Ukraine to get the idea of transition across, joining a long line of great photographers to work in the public transport field - Walker Evans, TomWood, Bill Sullivan, Robert Frank, Daido Moriyama and Luc Delahaye just a few who spring to mind.
Below Georgiou talks about the importance of finding, and losing, the familiar.
"When you first arrive in a place, you are so informed by images you have already seen that it is a burden you have to lose," says George Georgiou, the London-based photographer who has recently returned from 8 years working in Turkey, the Balkans and Eastern Europe. "The next thing you do is look for difference, which is something else you need time to get over. Once you have done that, you start to look at what is familiar and then, and only, then can you appreciate what is different - because only then can you appreciate that it is really different."
I'll put the full text up later. In the meantime, read more on Curious George Georgiou in this week's BJP.
No comments:
Subscribe to: Post Comments (Atom)


text:
Examination Process
PLEASE NOTE: The following information applies to the essay examination format at the PearsonVUE Testing Center:
- You are required to read and accept the Non-Disclosure Agreement (NDA). If you do not accept the NDA within a given amount of time, you exam will be timed out and you will forfeit your exam fee;
- You will be given a white board for any notations during the exam;
- You will receive a tutorial before the essay examination begins, as well as instructions on how to navigate through the exam screens;
- You have a maximum of 60 minutes to develop a 4-part essay response for each case scenario;
- A time clock is located in the upper right hand corner of the computer screen and will track the time used. It is your responsibility to monitor the time available to complete each essay. If you fail to complete your essay response and are timed out, you will not receive a score for that response.
- You will receive a "WARNING FLAG" at 10 minutes before the time is up (e.g. at 50 minutes out of total 60 minutes for each essay);
- You may navigate back and forth between the "text box component screens" within the same essay by using the back/forward buttons. However, please note the scrolling feature as found in the EBAS website is not available at the Test Center;
- If you complete an essay before 60 minutes have elapsed, you must click "NEXT ESSAY SCENARIO" in order to proceed to the next one;
- Once you have moved to the next essay, you may not go back to a prior essay;
- At the end of the exam, you will be offered the opportunity to complete a post-exam survey. EBAS encourages you to send a written e-mail notification of any concerns within seven (7) calendar days from the date of the exam. Consideration will be given the written e-mail request during the Post-Exam Review Process.


text:
The smallest of the cage lampshades or the largest of the metal lamp holders?
The GhostBell naked metal lampshade cage with E27 chromed metal lamp holder kit is a simple, elegant and surprising solution to create multiple pendant lights, using a decorative LED bulb in the Edison ST64 shape and one of our 150 colors of textile cables.
Attention! Light bulb NOT included.
Naked light bulb cage lampshade GhostBell Black colored metal:
Material: painted metal.
Width: 12,5 cm.
Height: 17 cm.
Hole opening: 1 cm.
Not suitable for light bulbs with a diameter over 6,4 cm.
Chromed metal cylindrical E27 lamp holder kit:
Diameter: 4,2 cm.
Height: 6,2 cm.
Hole diameter: 1 cm.
Material: metal.
We ship all our orders using either Royal Mail or DPD services. Orders are usually dispatched within 24/48 hours, if the items are out of stock the dispatch time will be around 5-7 working days. See more details here.


text:
Creating art is therapeutic, stimulating, relaxing, and fun. It doesn't matter what type of art you make, it is good for you. Even when you're just around art it is good for you. Today, we look at the mental benefits of art. This explains why we at the Dalton Pottery believe so strongly in art and its therapeutic effects.
Creating art helps with creative thinking. Problem-solving is basically being creative to solve a problem that doesn't have an existing solution. When you create art, you practice the creative thinking and problem-solving parts of your brain. This also helps the brain cells to keep communicating and stay healthy.
Art helps the brain connectivity and plasticity. Your brain creates new connections every time you do something new. As you grow older this ability of the brain to grow, declines. It is called plasticity. Art helps to stimulate the communication between different parts of the brain and helps it to retain its plasticity.
Looking at art can change perceptions and feelings. When you visit an art museum, you see a lot of new things and you learn about the past and how other people experience the world. Studies have shown that this experience increases the empathy people have with others and the past. Many people experience looking at art like they would experience falling in love.
Creating art helps with releasing stress. When you are busy creating something, your mind pushes aside all other thoughts. This helps you to stop focusing on the troubles at work or home or whatever other worries you have. This gives the mind and body a break to relax.
Arts and music make better students. It has been proven that children who have art or music lessons from a young age perform better in subjects like maths and languages. This is important because art and music help the brain form more connections which increase plasticity and ensures a healthy brain and intelligent people.
Clearly, art is an important part of our lives. It not only teaches us about other people, their experiences, opinions and the past, but it also stimulates our brains to become and remain alert.


text:
The Kartoffellagerhallen was a series of brick buildings built in 1942 for the storage of potatoes, and in proximity, sheds for other vegetables such as cabbage (known as the Krautsilo). In between Camp I and Auschwitz-Birkenau, and on the east side of the Bahnhof West, 10 brick buildings were built by Jewish prisoners for the storage of potatoes that were grown around the camp field areas. Once completed, prisoners would work inside the sheds managing the rotation of stock and shipment. This kind of work allowed opportunities to smuggle out food to eat or to barter in the camp for other valuable items essential for survival, such as shoes, warmer clothes and medicine. Survivors of the earlier transports arriving at the original Judenrampe remember seeing the row of potato sheds and mentioned them in their testimonies. When transports were arriving, the security around the area was heightened in a circle with a line of sentry guards, dogs and watch towers.
Just at the end of the row of sheds at the north tip, the so called Krautsilo was built for the purpose of souring cabbage. 2 more potato sheds were built at the south east tip of Auschwitz-Birkenau section B1 and other temporary stores were used in the large Industriehof area. At the south end of the sheds, a rail line ran parallel and beyond until it reached the Zerlegebetrieb, the Auschwitz scrap metal yard in the direction of the village Harmęże.
The row of ten sheds were still in reasonable condition including the original doors until the year 2000 when a fire ripped through complex. The roofs have mostly been destroyed but the brick frame is still intact. Since the fire, the area has succumbed to the anti social element in the town and is a prime location for fly tipping, graffiti and drinking. In 2015, Belgian journalist Thomas Van De Putte who was researching a television documentary informed the town authorities of some anti-Semitic graffiti on the larger potato sheds. Only when he revealed his involvement in a documentary on the town, he was able to persuade action. As a result, the graffiti was eventually painted over.
Unfortunately the responsibility of maintenance and respect for this location has not been taken by anyone except for the 2 barracks to the south west of Birkenau that only came under the protection and preservation of the Auschwitz-Birkenau museum just after they fell in ruins. In 2014, a new wooden roof support was seen at the foot of the sheds insinuating the immediate preservation was taking place to keep the structure of the building intact.
Information about sources we used while researching the industrial zones of Auschwitz you can find here.


text:
Researchers Discover Link Between Organ Transplantation And Increased Cancer Risk
July 27, 2017
Researchers have determined a novel mechanism through which organ transplantation often leads to cancer, and their findings suggest that targeted therapies may reduce or prevent that risk.
In the July 15, 2008, issue of Cancer Research, researchers at Harvard Medical School found in animal and laboratory experiments that the anti-rejection, immunosuppressive drug cyclosporine ramps up expression of vascular endothelial growth factor (VEGF), which signals the growth of new blood vessels that can feed tumors.
They also found that simultaneously administering an anti-VEGF therapy with cyclosporine in mice repressed this tumor growth. Several inhibitors of VEGF are already in use in human cancer therapy.
The findings could offer some good news for the 15 to 20 percent of transplant patients who develop cancer within a decade of receiving new organs, according to the study's senior investigator, Soumitro Pal, Ph.D., an assistant professor at Harvard Medical School's Transplantation Research Center at Children's Hospital in Boston.
"It may be that anti-VEGF agents given judiciously after transplantation can reduce future cancer occurrence," he said.
VEGF expression is markedly increased in patients post-transplantation, and this can aid in the development of a blood supply to a transplanted organ, helping it survive and thrive. "But once the organ has stabilized, it may be possible to lower the level of VEGF expression to prevent tumor growth," he said. "We would need to figure out how to balance benefit and risk to keep cancer at bay."
Tumors that develop after transplantation may have three potential sources: they may have pre-existed or could have been a recurrence of previous cancer - and in both of these cases, a patient's pre-transplant immune system might have kept these cancers in check - or cancer-causing viruses could have come from the donor organ. Physicians have long observed that immunosuppressive agents, such as the class of calcineurin inhibitors that includes cyclosporine, appear to promote cancer development, often in organs that are not transplanted, but the cause of this was unclear. The Harvard team tested the ability of cyclosporine to promote growth of pre-existing tumors in mice implanted with human renal (kidney) cancer cells. Mice treated with the agent formed tumors faster than untreated mice, but anti-VEGF therapy substantially reduced that excessive growth.
Digging deeper into the biological pathway of VEGF activation, the scientists found that cyclosporine activates two of the three forms of the common protein catalyst, protein kinase C, which leads to increased expression of VEGF.
"We think PKC-mediated VEGF transcriptional activation is a key component in the progression of cyclosporine-induced post-transplantation cancer," Pal said. "It is likely not the whole story, but this gives us a clue that we might be able to use existing or novel therapies to reduce cancer risk in transplanted patients."
The mission of the American Association for Cancer Research is to prevent and cure cancer. Founded in 1907, AACR is the world's oldest and largest professional organization dedicated to advancing cancer research. The membership includes more than 28,000 basic, translational and clinical researchers; health care professionals; and cancer survivors and advocates in the United States and 80 other countries. AACR marshals the full spectrum of expertise from the cancer community to accelerate progress in the prevention, diagnosis and treatment of cancer through high-quality scientific and educational programs. It funds innovative, meritorious research grants. The AACR Annual Meeting attracts more than 17,000 participants who share the latest discoveries and developments in the field. Special conferences throughout the year present novel data across a wide variety of topics in cancer research, treatment and patient care. AACR publishes five major peer-reviewed journals: Cancer Research; Clinical Cancer Research; Molecular Cancer Therapeutics; Molecular Cancer Research; and Cancer Epidemiology, Biomarkers & Prevention. Its most recent publication and its sixth major journal, Cancer Prevention Research, is dedicated exclusively to cancer prevention, from preclinical research to clinical trials. The AACR also publishes CR, a magazine for cancer survivors and their families, patient advocates, physicians and scientists. CR provides a forum for sharing essential, evidence-based information and perspectives on progress in cancer research, survivorship and advocacy.
American Association for Cancer Research


text:
About Crane Controls
Intelligent Positioning and Control of Automated Cranes, Hoists, AS/RS
Trutegra is an industry leader in automated crane technology and positioning systems.
Over the past ten years Trutegra has developed advanced solutions for control of…
- Cranes
- Hoists
- AS/RS and similar automated material handling systems
- T-cars
- Shuttles
- Plating Lines
The emphasis on Research and Development, specifically focused on crane and material handling systems, has allowed the development and deployment of reliable solutions for…
- Skew Control
- No-Sway
- Obstacle Avoidance
- Coordinated Multi-Axis Moves
- Advanced Safety and Redundancy Features
Trutegra's sophisticated Level 1 controls (machine level) are designed to reduce the demands on Level 2 (warehouse management) systems, thereby reducing overall system complexity, and improving reliability and maintainability.
Controls Are Designed for:
- Safety is an integral part of all Trutegra systems. We meet industry safety standards and utilize safety PLCs when required, along with the many implementations of our Obstacle Avoidance and Collision Avoidance Systems.
- The latest software and hardware is used to help you be confident in the reliability of your system. In addition to this, solutions are extensively tested for proof of concept in the Trutegra Crane Lab before continuing onto the plant floor.
Optimum productivity
- We strive to get you what you need in an efficient and effective way. By simulating your system in our lab before implementing, we can ensure minimal downtime during installation.
- Trutegra systems are built on platforms by global leaders, such as Allen-Bradley and Siemens. By using modern programming tools and well organized code structure, our systems can be easily maintained by plant personnel. We also offer 24-hour emergency service in the event that something were to happen on the production floor.