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View Diary: $166 Billion put in Offshore Accounts by 60 US Corporations in 2012 to Avoid Taxes (31 comments)

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  •  re: the loan: I don't think that would work. (0+ / 0-)

    In your example, the US company deducts the interest expense on its repayments to the foreign sub, but, of course, the interest income of the foreign sub is Subpart F income and is immediately taxable to the parent company.  So it's, at best, a wash for tax purposes.

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