id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-2852	Miller, David S.	Tax Planning Under the Destination Based Cash Flow Tax: A Guide for Policymakers and Practitioners	2017	14	.pdf	application/pdf	5150	211	51	Because a sale by a U.S. multinational to its Irish subsidiary would be exempt from U.S. tax, the U.S. multinational would seek to maximize the transfer sales price. The Irish subsidiary would avoid U.S. federal income tax because it would not have a permanent establishment in the United States by reason of all activities being conducted through an independent agent.	cache/taxlaw-2852.pdf	txt/taxlaw-2852.txt