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Edward D. Kleinbard

Edward D. Kleinbard

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The Global Tax Avoidance Dance

Posted: 03/31/11 06:48 PM ET

America's most successful multinationals make great products and offer superior services. But they have another, less enviable quality in common -- they have become world leaders in tax avoidance.

General Electric's global effective tax rate for 2010 was 7.4%. Pfizer's was 11.9%; Cisco came in at 17.5%. The nominal U.S. corporate tax rate is 35%.

Each company has its own tax story, but all -- like other multinationals -- have for years relied heavily on low-taxed foreign income to drive down their worldwide tax obligations, including those of their U.S. businesses.

American multinationals claim they are taxed on their worldwide income, but in reality the "active" income they earn through foreign subsidiaries is not taxed in this country until the cash is repatriated. In addition, financial accounting practices (the lens through which we view these firms because their tax returns are not public) permit a company not to book any U.S. tax liability on foreign earnings if the firm states that the income is "indefinitely invested" abroad.

General Electric has $94 billion in indefinitely reinvested earnings. The total for corporate America is more than $1 trillion. 


If the story was simply that U.S. firms have successfully expanded into international markets and are paying taxes abroad at lower rates, one could argue that there is no U.S. tax mischief afoot. But these are not the facts.

Tax collectors in the U.S. and in high-tax foreign countries are the direct victims of the tax avoidance, but we all suffer from the resulting budget deficits and distorted investment decisions that firms make as a result of their ability to generate what I call "stateless income" -- income derived from selling goods and services in a high-tax country but that, through internal tax legerdemain, surfaces in a low-taxed affiliate.

What's going on is a highly choreographed six-step dance.

Step 1: U.S. firms rely on aggressive "transfer pricing" to sell, at bargain prices, high-profit U.S. assets or business opportunities to their low-taxed foreign subsidiaries in countries like Ireland. It cannot be simply the luck of the Irish that explains the extraordinary profitability of the Irish subsidiaries of U.S. firms relative to their European sister companies.

Step 2: U.S. multinationals move income from higher-tax foreign countries, where their customers actually are located, to lower-taxed ones not only through transfer pricing but also through "earnings stripping." For example, a corporation funds its German subsidiary with loans secured in Ireland, so the interest is deductible in Germany.

Step 3: Not satisfied with low corporate tax rates in Ireland (12.5%) or in other countries, U.S. firms set up exotic internal funding structures -- with such names as "Double Irish Dutch Sandwich" -- to shift income from these countries to zero-tax havens like Bermuda.

Step 4: Firms arbitrage what remains of their U.S. tax base by parking their global external-debt financing here, which creates interest deductions to shield their U.S. income. They then overstuff their low-taxed foreign subsidiaries with equity capital.

Step 5: Having put their stateless-income generating machines in motion, U.S. firms let their ultra-low-taxed foreign income accumulate abroad. Microsoft, for example, has accumulated $29.5 billion in offshore indefinitely reinvested earnings. Its financial statements suggest that its effective foreign tax rate from selling its products and services to customers located primarily in populous and relatively high-tax countries is in the neighborhood of 4%.

Step 6: With more than $1 trillion in low-taxed earnings offshore, the firms complain to Congress that U.S. tax law impedes their ability to reinvest their foreign earnings back home because they have not yet paid U.S. taxes on them. They demand a special tax holiday from Congress so they can complete the circle and repatriate all those earnings at nominal cost.

All this tax engineering has yielded tax burdens that bear no relationship to tax rates in the United States or in the populous foreign countries where the firms actually have personnel, real investment and customers.

It's true that the U.S. corporate tax rate, at 35%, is too high relative to its economic peers, about 28% on average. (Click here for data on the 31 member states of the OECD; the 28% figure is an unweighted average of the larger OECD members. Click here for the "BRICs" and other non-OECD countries.) But the solution is not to reward U.S. multinationals for concocting and implementing worldwide tax-minimization schemes.

The only feasible solution is to lower the U.S. rate to a level comparable with global norms and to pay for the reduction in part by introducing worldwide tax consolidation for U.S. firms, just as they today consolidate their worldwide operations for financial accounting purposes.

Edward D. Kleinbard, a professor of law at the University of Southern California Gould School of Law, is former chief of staff of the U.S. Congress' Joint Committee on Taxation. The facts and arguments in this piece are abstracted from two recent papers authored by Prof. Kleinbard: Stateless Income and The Lessons of Stateless Income. 




 
America's most successful multinationals make great products and offer superior services. But they have another, less enviable quality in common -- they have become world leaders in tax avoidance. Ge...
America's most successful multinationals make great products and offer superior services. But they have another, less enviable quality in common -- they have become world leaders in tax avoidance. Ge...
 
 
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wmnorton
Moderate where moderate used to be
01:38 PM on 04/03/2011
Some industries like Blockbuster are dying of natural causes, others like apparel are being murdered. When Nike and other companies like them can make a pair of shoes for $2.50 overseas but still charge $100 for them in the American Market we are all being taken advantage of. $100 is what those shoes should cost if they had been made in this country by union labor. But Nike claims that their profit is made overseas. We need to define profit as the money transfer at final sale. Then all of these international companies would be forced to pay a ligitimate tax rate because these obscene profit are not available without accesss to the American market place. The only way to fix this is to declare all of the free trade agreements void and impose a value added tax on all imported items where a value added tax is imposed on our exports.I would also get rid of the !5% dividend tax rate on individuals in exchage for a lower (25%)corporate income tax rate. Make it clear to the top 2% they can not have both.
08:01 PM on 04/02/2011
Some people like to eat and then do everything possible to avoid paying.

Many rich people and corporations are like that.

They benefit from everything a country (America for example) has to offer and then turn around and do everything possible to avoid taxes.

Greed, selfishness, and no ethics. Also, NO patriotism to their country.

Sickening and sad.

It is even worse when politicians aid and abet due to campaign money given.
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AlanBannacheck
President of the Deep Thoughts Association (DTA)
06:27 PM on 04/02/2011
This is hardly a surprise and it begs the question on who or what owns these "tax free havens." However I don't see our politicians doing much about it. After all they may work for one of these companies after their government career.
01:33 PM on 04/02/2011
Mr. Kleinbard,

Am I correct in this: if an individual does what these corporations do, he or she would go to jail?
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LeftRight
TANSTAAFL
05:01 PM on 04/02/2011
Yes you are. And then there's the fact that slavery (the owning of a "person") is illegal, and yet corporations own other corporate "persons" all the time....
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TheHat921
05:30 PM on 04/02/2011
As a fellow tax lawyer, please let me answer for Mr. Kleinbard.

Individuals cannot utilize income shifting techniques in the same way a business (i.e., corporate) taxpayer can! Indeed as pointed out by others, wage earners (as opposed to those who earn income on equity) have very little they can do to avoid the "marginal" tax rates associated with their earnings. Indeed the alternative minimum tax made this even more draconian than heretofore.

Corporations don't "go to jail" as non-persons, and even theri executives bear no criminal responsibility for aggressive tax positions unless those executives are so inept that it does not bear mentioning.

Big tax accounting firms have, on occasion, paid with large fines and serious threats of criminal sanctions, due to highly aggressive tax advantaged structuring...but now that they've been "wacked" they noiw leave the aggressive stuff to the Kleinbard's and others like yours truly.
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La Bennett
12:43 PM on 04/03/2011
Which is why some things need to change. SCOTUS just said a corporation is a person, treat them, and their executives as such. Also change the rules so any income made in the US is taxed, no credit, no breaks, etc.. Also change the fine structure so that when caught, the fine is 1000 times the amount of the amount "avoided". Make it a CRIMINAL offense for any CEO/CFO/accountant or tax attorney, to allow the avoidance of paying taxes or sheltering income off shore. Make the fines be payable by each involved party, 1000 times for the Company/Owners/CEO/CFO/Tax Firm/Account/Attorney each one pay an individual fine equal to 1000%, make it hurt to cheat, and to encourage or help cheaters. Do away with the tax code that has been tweaked by lobbyist and special interests. Flat amount on all income, and in the case of managers and executives extend that flat tax to include as income any benefit (food, clothing, transportation, benefit) that every employee of the firm does not receive. Period.
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terramartom
People for the people. Revolution.
10:20 AM on 04/02/2011
This is no less than treason being committed by Global US companies enabled by crooked politicians!
America has been degraded into the opposite of what it suppose to stand for by greed, and the country slide into decline like every other country in History.
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TheHat921
05:34 PM on 04/02/2011
No, this is not reason by corporations....anyone will tell you that a corporation and its handlers do not feel a sense of "nationality".

This is besides the poitn anyway; re-read Kleinbard's article. As his scholarly article states, the code and reasonable positions allowed under the code allow corporations to completely avoid the 35% federal effective rate. The rate is a cruel joke; it is too high, but rarely paid. The real effective tax rate paid by most (see "GE Capital" and its tax lawyers) is legally miniscule, and so all the griping by corporations is defensive and not to be taken seriously.

By the way, lower taxes on a federal level will not equal more US jobs. Too much to explain here, but trust me on that one!
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La Bennett
12:46 PM on 04/03/2011
yeah, isn't funny that the only ones that have to truly pay the higher tax rate, are the "small Businesses", who cannot afford lobbying or special interest breaks in congress. You know the same small businesses that every single politician says is the key to turning the economy around, the ones that are the true "job creators"?
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macro focus
Change the Narrative.
09:34 AM on 04/02/2011
RED66 2 hours ago (7:45 AM)

"We should return to a Constituti­onal government instead of the hugely wasteful and inefficien­t leviathon we have now."

-------------------------
RED66, got it. But that's more of a campaign slogan rather than a policy statement. That's not a criticism, I'm just more interested in details.

So would you say that you approve of government and you also approve of taxes? But you want less taxes? Is that correct? And would you say you want zero federal spending on education and the "social safety net?" Is that accurate?
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RED66
We must return to a Constitutional government.
12:59 PM on 04/02/2011
I approve of a federal government that returns to abiding by the US Constitution. There is no power for the feds to be involved in Social Security, welfare, and on and on.

States can do that and do it more effectively.

The sole purpose of a moral government is to protect the rights of individuals from force and fraud.

It cannot protect us from ourselves.

To do this, government needs money. Taxes work although the current US system is rife with corruption since lobbyists can give money to politicians for a little additional rule exempting their interest.

The Fair Tax would end this.

There are over 17,000 pages of regulations and laws. It's impossible for anybody to follow them.

The GAO just reported hundreds of duplicate programs. This is the result from the federal leviathan since nobody knows the scope of the federal government. We just keep adding to it.
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TheHat921
05:41 PM on 04/02/2011
RED66 and others who have locked on to the position that much of what the US government does now is "unconstitutional", have locked onto absolutely nothing of any value!

The courts determine what is and what is not legal and the US Supreme Court determines what the Constitution permits. It is stare decisis, long held decided principles of law, that the US government through Congressionally passed legislation can do everything that it currently does; either under the obvious stated rights (defense), the commerce clause (including the dormant commerce clause), and the "privileges" clause.
Moreover, Social Security, Medicare, Medicaid, etc. etc. were all fought and determined to be constitutional.

Those original intent followers state that their positions are clearly right under the founders intent, but they really can't point to legal principles that provide that the consitution was meant by the founders to be interpreted as a static document.
08:40 AM on 04/02/2011
The solution to minimum taxes for American based companies is all too simple......a miniumun tax based on sales.

You move a top 2000 company out of this country......a mandatory import duty tax.

For countries that have labor rates less than 25% of those in America an import duty where all funds to directly to Green Technology funding and other growth markets..... and distributed on the fastest time to market first basis. Jobs, Jobs, Jobs

We are the largest market in the world in terms of purchases from overseas.......lets start acting like it for leverage and to help America and Americans.

>>>>>>

Ofcourse none of this or anything that really will help American can ever happen.......somehow we need to fix the legislative process, maybe something like this

Time is up….this is the time for an all new approach ....with todays technology we do not need Congress to have the FINAL vote for us on key and critical matters that we could actually vote on ourselves today.
 
This is the best time in history to make the change for Congress to continue as before, but citizens of this country actually have the FINAL vote on key and critical legislation.
 
I challenge everyone to view the articles on the Huffington front page today/this week and determine how many issues/problems stated would not exist if we the people had the FINAL vote on key and critical legislation.
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BluePhantom2
The Blacksmith & the Artist reflected in their art
08:10 AM on 04/02/2011
Simplifieng the tax codes is something the lawyers and politicians are not going to let happen without a fight. But it is a fight worthe having! A flat tax for everybody (Starting at 30k, so the lower income folks don't have to pay) of 15-20% with no deductions, special rules would solve all kinds of problems. A balances budget ammendment would help too!
Ineresting article: Been seeing/reading alot about GE paying no tax's this year and everybody all up in arms about GE following the rules that our politicians/lobbiests/lawyers made this is pure theater by both sides and totally misses the point which is probably the point?
ScaredAcademic
The GOP: Peddling Hate Since '68
12:15 AM on 04/02/2011
He almost has it. He leaves out the fact that it is really lawyers and lawmakers that interact to produce all of this. The law school/lawyer monopoly and their lack of interest in simplifying or unifying the system lest their services be rendered unnecessary drives the other side of why fixing it is so hard.
09:10 PM on 04/01/2011
Not much in the way of patriotism of the corporate "person". They routinely uproot themselves and leave the U.S.. Tax cuts for leaving grease the way. Certain members of both parties have been and continue to be partakers and facilitators of massive job loss. They won't take suggestions.
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mrclark
I search for the America I believed in as a boy.
08:56 PM on 04/01/2011
We need to tax all multinationals on any item sold in the united states at 30% if it is made in a foreign country. Let the tariffs come up for it would be in the average Americans best interests. Foreign countries have VAT taxes on imports which means that we are essentially paying tarriffs on anything we are selling in those countries while in America we are not taxing imports. Economic warfare has been ongoing for the last thirty years but those "free traders" who exist in America are mouth pieces for corporations that are getting wealthy while it is decimating the middle and foreign classes of America.
http://www.ehow.com/list_6796594_china-vat-tax-import-duties.html
08:33 PM on 04/01/2011
It's really all a charade though staged for the benefit of the dumbed-down public...

They pay tons of money to lobbyists to get Congress to write the rules this way.......and then when folks start howling about them not paying taxes, then they start complaining about how they would love to bring all that money back home if only tax rates were significantly lowered...

However, if you want to eliminate potential competitors.....or at least keep them at arms length, then the obvious solution is to subject those smaller competitors that are trying to get off the ground to overbearing taxation and regulations so that they can't compete with your armies of lawyers, accountants, and lobbyists who create those rules and can navigate through them for you (because in essence they were written specifically for your company in the first place).
ScaredAcademic
The GOP: Peddling Hate Since '68
11:47 PM on 04/01/2011
The law&politics complex that is not unlike the military-industrial one that Eisenhower thought fit to warn us about (that also still exists).
06:35 PM on 04/01/2011
Edward is indulging in obvious scapegoating. The amount of revenues owed by people who are behind in paying or otherwise evading taxes is piddling compared with the amount of revenues that we should be getting from rich individuals and corporations whose lobbyists have rewritten that tax code so that they don't have to pay.
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Lorianne
ama vitam
04:30 PM on 04/01/2011
The 19 Percent Solution
How to balance the budget without increasing taxes
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Daphydd
Lets play some music
04:49 PM on 04/01/2011
I stopped reading when the article unjustifiably stated that tax revenue cannot be increased.
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TMS3100
Tea Party has run off with his light saber.
04:59 PM on 04/01/2011
It has been shown over time that tax revenue equalizes at about 19% of the GDP. If you increase taxes, there will be a short term bump, over time collections go back to 19% of the GDP.
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Lorianne
ama vitam
05:16 PM on 04/01/2011
Thanks for taking time to inform me that you won't read the article.
I really needed to know that.
05:35 PM on 04/02/2011
Unfortunately, most elected officials don't have the spine to implement such a plan. And the ones who do tend to get marginalized by the media (ex. Ron Paul in the 2008 primaries). Even the so-called Tea Party people would probably fall to pieces if they took the time to actually educate themselves on what it's REALLY going to take for our country to become solvent again. Sadly, I'm trying to coach myself into being able to cope with debt that will greatly exceed 100% of GDP in coming years...debt that will never come down since the standard political dance is as follows:

1. Don't cut spending during a downturn...it'll make things worse

followed by

2. Don't cut spending during a strong rebound...we don't want to risk a downturn or a slowdown in recovery

So the cycle of irresponsible behavior continues...
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TMS3100
Tea Party has run off with his light saber.
06:10 PM on 04/02/2011
Very true.
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RED66
We must return to a Constitutional government.
04:19 PM on 04/01/2011
If nobody likes my first recommendation, how about this:

All nations end their taxes and the UN decides how much everybody should pay.