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Yes you want profits to be earned in the lower tax-rate jurisdiction. What you describe is the typical tax strategy: direct profit to the lower-rate country then leave it there.

The economic value is in deferral of tax. A dollar of tax paid next year has a lower present value than a dollar of tax paid today.

You need a lot of deferred tax to make this cost effective. If you are postponing the payment of $100,000 of tax that means you have $100,000 of extra cash in the bank that would have gone to the tax man. What can you do with it? Earn 1% in a bank? Whee! That won't pay for much of Phil's legal fees. :-)

It is a game for big companies.

For most companies, keep it simple is the strategy. Deferral won't generate a big enough economic benefit.




Thanks for humoring me. I took 2 tax courses a very long time ago (got A's in both of them). But I suspected my knowledge wasn't very practical.




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