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7 OPERATING THROUGH JOINT VENTURES UNDER U.S. INTERNATIONAL TAX RULES: GLOBAL COMPETITION FOR R&D INVESTMENTS
Pages 81-84

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From page 81...
... As an illustration, I recall being involved in a negotiating regarding the acquisition of an interest in a company operating outside the United States. The owner would not sell a controlling interest but would sell 49 percent of the business.
From page 82...
... In the case of United Technologies Corporation, more than 50 percent of our revenues and profits for 1996 and substantially more than 50 percent of our income tax expense are generated in jurisdictions outside the United States. We and other U.S.-based corporations are now paying significant income tax to foreign governments.
From page 83...
... This compares to the $45 benefit in the case of the United States and constitutes a major competitive advantage. Given this choice and other considerations being equal, a U.S.-based corporation will choose to make the R&D investment in Canada, reduce its tax burden and its effective tax rate, and maximize its profit.


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