🧵One argument I've heard against closing the round-tripping loophole goes like this:

“But we only have round-tripping income because we acquired an Irish pharma company that was selling to the United States. We weren’t trying to game the system.”

A response:

1/ What exactly is an “Irish pharma company”? Let’s peel back this onion. These aren't homegrown Irish pharma companies founded by Irish entrepreneurs. The image of some enterprising Irish chemists attracting investors to start a pharma company is largely fantasy.

2/

🧵 Petitioners’ SCOTUS brief claiming TCJA’s deemed repatriation is unconstitutional rests on two incorrect assertions:

1. Lack of control
2. Lack of realization

The problem for petitioners is that both control and realization exist.

1/

https://twitter.com/alanmcole/status/1696966947294851150

1. CONTROL: Recognizing the particularly high risk of tax avoidance when US shareholders (SHs) hold stakes in foreign (as opposed to domestic) companies, Congress in 1962 defined “control” as 5 or fewer 10% or greater US shareholders together owning > 50% of a foreign corp.

2/

The @JesseDrucker article template:

1. Identify tax break
2. Confirm high-income people/corporations receive benefit
3. Intentionally misrepresent material facts
4. Assert corruption
5. Inflame readers sense of outrage
6. Rinse/repeat

THREAD 1/10

nytimes.com/2020/04/24/bus… MISREPRESENTATION: "One provision... increases the amount of deductions companies are permitted to take on the interest they pay on large quantities of debt. Only companies with at least $25 million in annual receipts can qualify for that break."

2/10