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Focus on International Tax: U.S. Taxation of International Operations - Potential for Reform? Print

Once again the news notes a GAO study pointing to the relatively high rate of foreign companies paying little tax on their US operations. The cries for international tax reform again join with other election-year issues.

When considering potential areas for reform, one fundamental issue is how does the US tax rate compare? With countries such as Ireland having much lower tax rates - 12.5% versus the US' 35%, one possibility is a simple reduction in the corporate tax rates.

Other reform efforts may be focused on increasing collections, especially in the areas of "perceived abuse" like international taxation. For example, IRS may be mandated to take a more focused look at the tax return reporting of intercompany transactions. Under IRS regulations, businesses must have contemporaneous documentation on how their transfer prices approximate arms length transactions. Additional information reporting may be required. Improving taxpayer's requirements to self-report details about intercompany transfer pricing could provide IRS with more automatic auditing of international operations.

For more information, contact:

Linda Paradis, CPA
Partner
Tax Consulting Services Group
314.290.3382
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