In the second part of her analysis of Caterpillar’s tax affairs following the company’s appearance before the Senate Subcommittee on Investigations, Mirna Screpante, tax researcher, looks at the division between the location of activities and the location of taxable profits and proposes a method for determining economic substance.
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The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
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