id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-2822	Garbarino, Carlo	The Use of Cross-Border Corporate Profits and Losses and “Global Corporate Tax Information”: A Game Theory Approach	2014	37	.pdf	application/pdf	22462	657	37	Once foreign activities become profitable, US taxpayers are encouraged to transfer those activities to controlled foreign corporations, in order to defer US tax on the foreign-source income.83 Second, foreign corporate losses and other deductions may be transferred to the US domestic tax jurisdiction by multinational firms that thereby capture tax rents. Symmetrically, the Panel's proposal would disallow domestic deductions for costs directly allocated to exempt foreign-source income, as well as interest (allocated under a worldwide apportionment approach) and overhead expenses allocated to exempt foreign-source income.93 When the US in all the instances described above allows effective consolidation in the US of foreign corporate profits and losses, and interacts with a country that is adopting a domestic tax consolidation system which unilaterally protects its own tax base, the US has a dominant unilateral strategy which may not protect US tax base.	cache/taxlaw-2822.pdf	txt/taxlaw-2822.txt