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Controlled Foreign Corporation Rules and Cross-Border M&A Activity [PDF]
SSRN Electronic Journal, 2017 We investigate the influence of one main anti tax avoidance measure, controlled foreign corporation (CFC) rules, on cross-border merger and acquisition (M&A) activity on a global scale. Using three different statistical methods and a large M&A data set, we find that CFC rules distort ownership patterns due to a competitive advantage of multinational ...
Hagen, Dominik von, Prettl, Axel
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Controlled Foreign Corporation and Importance of Exchange of International Information
International Journal of Public Finance, 2020 Countries that want to take a share from the funds and capital flows of the saving countries and companies have started to make tax arrangements in order to get a share from the market in question with their unfair competition.
Taner Ercan
doaj +2 more sources
An Economic Rationale for Controlled-Foreign-Corporation Rules [PDF]
, 2014 By introducing controlled-foreign-corporation (CFC) rules, the parent country of a multinational firm reserves the right to tax the income of the firm's foreign affiliates, if the tax rate in the affiliate's host country is below a specified threshold.
Mardan, Mohammed +2 more
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Impact of Controlled Foreign Corporation Rules on Post-Acquisition Investment and Profit Shifting in Targets [PDF]
SSRN Electronic Journal, 2017 We investigate real investment, financial revenues and profits in formerly domestic firms once they enter a multinational entity (MNE) through an acquisition. We argue that following the acquisition, those targets are tax-optimized in a profit shifting context if they are acquired by MNEs with no controlled foreign corporation (CFC) rules in their ...
Hagen, Dominik von, Harendt, Christoph
openaire +5 more sources
Due to the Gloomy Economic Outlook EU Fight against Tax Havens Enters a New Phase [PDF]
Revista de Management Comparat International, 2021 An important part of the massive loss of income registered by some states of the European Union is due to the tax havens. It is estimated that last year alone the impact at EU level was 75 billion Euros.
Narciz BĂLĂȘOIU
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Controlled foreign companies of Russian residents in the context of world trends
RUDN Journal of Law, 2021 The subject of this article is financial relations of the state and its tax residents with foreign assets (stock), as well as control over such companies through various legal mechanisms.
Evgenia E. Frolova, Ekaterina A. Tsepova
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RESTRAINING HARMFUL TAX COMPETITION: AN ANALYSIS OF AMERICAN CFC LEGISLATION
Ekonomia i Prawo, 2014 Capital and labor mobility facilitates cross-border activities of enterprises. In the era of globalization the optimal choice of investment location gives enterprises an opportunity to profit maximization.
Małgorzata Magdalena Hybka
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Abuses and Penalties of a Corporate Tax Inversion
International Journal of Financial Studies, 2019 There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S.
James G. S. Yang +2 more
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CFC Legislation, Passive Assets and the Impact of the ECJ's Cadbury-Schweppes Decision [PDF]
, 2013 In its Cadbury-Schweppes decision of 12 September 2006 (C-196/04), the Court of Justice of the European Union decided that the UK controlled foreign corporation rules, which were implemented to subject low taxed passive income of foreign affiliates to UK
Ruf, Martin, Weichenrieder, Alfons
core +1 more source
Financial Theory and Practice, 2014 Tackling corporate profit shifting requires appropriate anti-avoidance measures. This article reviews one of these measures, a controlled foreign companies (corporations) regime.
Magdalena Małgorzata Hybka
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