id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-2850	Avi-Yonah, Reuven S.; Clausing, Kimberly	Problems with Destination-Based Corporate Taxes and the Ryan Blueprint	2017	27	.pdf	application/pdf	11108	453	53	The base company rule, I.R.C. § 954 (2015), provides that selling goods or services through a “base company” in a low-tax jurisdiction triggers U.S. tax to the parent, and I.R.C. § 956 (2007) provides that using income otherwise eligible for deferral to invest in U.S. property (including a loan to the parent) triggers U.S. tax to the parent. This means that products, services and intangibles that are exported outside the United States will not be subject to U.S. tax regardless of where they are produced.	cache/taxlaw-2850.pdf	txt/taxlaw-2850.txt