Recommended Citation

Jeffery M. Kadet and David L. Koontz, Letter from Jeffery M. Kadet and David L. Koontz to the Internal Revenue Serv. (June 5, 2018) on Notice 2018-43, 2018-2019 Priority Guidance Plan Regulatory and Ruling Guidance Concerning Various International Tax Issues (2018), https://digitalcommons.law.uw.edu/faculty-articles/495

Authors

Jeffery M. Kadet, University of Washington School of LawFollow
David L. Koontz

Letter from Jeffery M. Kadet and David L. Koontz to the Internal Revenue Serv. (June 5, 2018) on Notice 2018-43, 2018-2019 Priority Guidance Plan Regulatory and Ruling Guidance Concerning Various International Tax Issues

Document Type

Response or Comment

Abstract

A principal focus of our suggestions is the modernization and updating of regulations as well as providing guidance that will affect the many multinational corporations (MNCs) whose operations take place partially or wholly within the U.S. Many of these MNCs have embarked on complicated and legalistic schemes whose primary purpose is to shift profits without any real operational changes and to record those profits within zero- and low-taxed foreign members. Importantly, this includes not only U.S.-based MNCs, but also the many inverted MNCs that structured their inversions to remain untouched by the §7874 anti-inversion rules.