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In fact, as discussed in Chapter 2, many individuals in U.S. tax administration and enforcement believe that abuses are rife in inbound pricing cases, and tax revenues foregone annually as a result amount to billions of dollars. This belief is founded in part on comparisons of trends in foreign-owned assets and taxes collected from said owners over time: despite a tripling of foreign-owned assets, and a doubling of foreign-owned companies’ gross income earned in the U.S., total taxes collected from these companies remained nearly constant over a ten-year period. See Pear, Robert, “I.R.S. Investigating Foreign Companies over Units in U.S.,” New York Times, February 18, 1990. Concurrent decreases in corporate tax rates do not fully explain this pattern.
See Testimony by Mr. Frederick T. Goldberg, Jr., Commissioner of Internal Revenue, before the Subcommittee on Oversight, House Committee on Ways and Means, July 10, 1990, p. 85.
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(2004). The Resale Price Method. In: Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice. Springer, Dordrecht. https://doi.org/10.1007/0-306-48218-5_4
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DOI: https://doi.org/10.1007/0-306-48218-5_4
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