That Old Black Tax Magic
Never let it be said that the Internal Revenue Service stands by and watches as yet more US companies peer into the abyss.
It has quietly altered the rules on returning foreign profits to the US without triggering a US tax charge on those profits, in the hope that the subsidiaries will waft all their cash back to the mother-ship, sorry, home of the free, thus loosening the noose around the necks of all those businesses struggling to get credit.
Of course, this only works if the foreign based subsidiaries have lots of cash, in itself somewhat unlikely, and the overall group is rock solid.
The liquidators of Lehman Brothers, currently attempting to extract over $8 billion dollars which was transferred to New York in the last desperate hours before it went down, would probably have some advice on how to do that legally.
And the OECD might be a little cross if the US makes a habit of it, since all those tax treaties the US has signed require reciprocity in such matters. It’s billed as a temporary measure on the IRS website, but then so was the Patriot Act…
– Chenier
Posted: 7th, October 2008 | In: Reviews Comment | TrackBack | Permalink