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GAO-03-194R 1 (2002-10-01)

handle is hein.gao/gaocrptapdf0001 and id is 1 raw text is: 



  SGAO

       Accountability * Integrity * Reliability
United States General Accounting Office
Washington, DC 20548





         October 1, 2002

         The Honorable Henry A. Waxman
         Ranking Minority Member
         Committee on Government Reform
         House of Representatives

         The Honorable Jim Turner
         Ranking Minority Member
         Subcommittee on Technology and
             Procurement Policy
         Committee on Government Reform
         House of Representatives


         Subject: Information on Federal Contractors That Are Incorporated Offshore

         Some U.S.-based multinational companies have found that the effective tax rate on
         income earned from foreign sources can be reduced if they are incorporated in
         countries that either do not tax corporate income at all or tax the income at a lower
         rate than the U.S. corporate tax rate. Consequently, some U.S.-based companies
         incorporate from the outset in these so-called tax haven countries.' In addition,
         some companies that were incorporated in the United States have reincorporated in
         tax haven countries through corporate inversion transactions.

         According to the Department of the Treasury, the term inversion is used to describe
         a broad category of transactions through which a U.S.-based multinational company
         restructures its corporate group so that after the transaction the ultimate parent of
         the corporate group is a foreign corporation.2 Generally, after an inversion
         transaction, shareholders of the former U.S. parent company hold stock of the newly
         formed foreign parent, and the operations of the company are unchanged. Treasury
         also noted that there has been a marked increase recently in the frequency, size, and

         1The term tax haven is generally used in research and the media to refer to countries that have no or
         nominal taxes. Multinational companies incorporated in a tax haven may have U.S. based subsidiaries
         that pay U.S. taxes. The Organization for Economic Cooperation and Development (OECD) has
         developed criteria for identifying countries that may engage in harmful tax competition in the form of
         tax havens.
         2 Department of the Treasury, Office of Tax Policy, Corporate Inversion Transactions: Tax Policy
         Implications (Washington, D.C.: May 17, 2002).


GAO-03-194R Federal Contractors Incorporated Offshore

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