If I Had A Hammer – A Creative Method For Repatriating Offshore Corporate Profits

Overview

In this era of corporate inversions, there seems to be a lot of mud-slinging going around. Congress and the current Presidential administration would like to label large multi-national corporations as traitors. Somewhere along the line, the people in government seemed to miss the part about a corporation's legal obligation to its shareholders. The Republican Party continues to clamor about the need to reduce the corporate tax rate, but it seems to me that most large corporations have already figured out how to win the tax game and have an effective rate that is far lower than their top marginal rate.

I was recently chatting with a friend of mine who is a top international corporate tax attorney that has worked for the largest law firms and served as tax director for Fortune 500 companies about the problem. He told me that the issue is not the corporate tax rate, but rather, the idea of being taxed at all on foreign profits.