U.S. Multinationals Bring Home Cash, Dodge $25 Billion/Year in Repatriation Taxes


Souce: Tax Prof Blog

Bloomberg, Dodging Repatriation Tax Lets U.S. Companies Bring Home Cash, by Jesse Drucker:

At the White House on Dec. 15, business executives asked President Obama for a tax holiday that would help them tap more than $1 trillion of offshore earnings, much of it sitting in island tax havens.

The money -- including hundreds of billions in profits that U.S. companies attribute to overseas subsidiaries to avoid taxes -- is supposed to be taxed at up to 35% when it’s brought home, or
“repatriated.” Executives including John T. Chambers of Cisco Systems
Inc. say a tax break would return a flood of cash and boost the economy.

What nobody’s saying publicly is that U.S. multinationals are already finding legal ways to avoid that tax. Over the years, they’ve brought cash home, tax-free, employing strategies with nicknames worthy of 1970s
conspiracy thrillers -- including “the Killer B” and “the Deadly D.”

Merck & Co Inc., the second-largest drugmaker in the U.S., last year brought more than $9 billion from abroad without paying any U.S. tax to help finance its acquisition of Schering- Plough Corp.,
securities filings show. Merck is also appealing a federal judge’s 2009
finding that Schering-Plough owed taxes on $690 million it had earlier
brought home from overseas tax-free.

The largest drugmaker, Pfizer Inc., imported more than $30 billion from offshore in connection with its acquisition of Wyeth last year, while taking steps to minimize the tax hit on its publicly reported
profit.

Disclosures in Switzerland and Delaware by Eli Lilly & Co. show the Indianapolis-based pharmaceutical company carried out many of the steps for a tax-free importation of foreign cash after its roughly $6
billion purchase of ImClone Systems Inc. in 2008.

Article: http://www.blacklistednews.com/index.php?news_id=12090.

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