Maarten de Wilde* Summary On March 31, 2021, U.S. President Biden released his ‘American Jobs Plan’, an ambitious proposal for large scale public investments in infrastructure and other priorities. That same day the American President announced plans to offset the costs of these investments with U.S. corporate tax increase proposals: the ‘Made in America Tax…

The inspiration for this post is “The Made In America Tax Plan” (https://home.treasury.gov/system/files/136/MadeInAmericaTaxPlan_Report.pdf) recently released by the U.S. Department of the Treasury to outline President Biden’s Administration’s outlook on taxation, notably in so far as the “internationalization” of taxpayers’ undertakings is concerned.  This is a much shorter version of and directly excerpted from comments I…

Raffaele Russo[1] “In those countries where income taxes are lower than in the United States, the ability to defer the payment of U.S. tax by retaining income in the subsidiary companies provides a tax advantage for companies operating through overseas subsidiaries that is not available to companies operating solely in the United States… The undesirability…