Is United States Corporate Tax Policy Outsourcing America - A Critical Analysis of the Proposed Tax Holiday for Trapped CFC Earnings

THE debate about how best to reform U.S. corporate tax policy has focused almost exclusively on making U.S. corporations more competitive globally. But the debate often glosses over tax policy\u27s effect on the ultimate beneficiaries of corporate success and failure—U.S. corporate stakeholders. The assumption often has been that healthy, competitive U.S. corporations equal healthy stakeholders—including shareholders, employees, and the U.S. populace as a whole. However, recent economic research has brought the assumption of trickle down success into question. This Article suggests an alternate path focused on enhancing the competitiveness of U.S. MNCs in the global economy while enhancing the welfare of U.S. corporate stakeholders. The Article concludes by suggesting an incremental reform to the current Subpart E regime that would allow U.S. MNCs to repatriate assets currently trapped in CECs at a low tax cost in exchange for targeted domestic re-investment commitments. This normative solution would have a substantially lower net federal budgetary cost to implement than other proposals currently circulating. [ABSTRACT FROM AUTHOR] Copyright of Villanova Law Review is the property of Villanova University School of Law and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder\u27s express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.

Innovation Offshoring:Asia's Emerging Role in Global Innovation Networks

Most analysts agree that critical ingredients for economic growth, competitiveness, and welfare in the United States have been policies that encourage strong investment in research and development (R&D) and innovation. In addition, there is a general perception that technological innovation must be based in the United States to remain a pillar of the American economy. Over the past decade, however, the rise of Asia as an important location for "innovation offshoring" has begun to challenge these familiar notions. Based on original research, this report demonstrates that innovation offshoring is driven by profound changes in corporate innovation management as well as by the globalization of markets for technology and knowledge workers. U.S. companies are at the forefront of this trend, but Asian governments and firms are playing an increasingly active role as promoters and new sources of innovation. Innovation offshoring has created a competitive challenge of historic proportions for the United States, requiring the nation to respond with a new national strategy. This report recommends that such a strategy include the following elements: output forecasting techniques ... Improve access to and collection of innovation-related data to inform the national policy debate; Address "home-made" causes of innovation offshoring by sustaining and building upon existing strengths of the U.S. innovation system; Support corporate innovation by (1) providing tax incentives to spur early-state investments in innovation start-ups and (2) reforming the U.S. patent system so it is more accessible to smaller inventors and innovators; and Upgrade the U.S. talent pool of knowledge workers by (1) providing incentives to study science and engineering, (2) encouraging the development of management, interpretive, cross-cultural, and other "soft" capabilities, and (3) encouraging immigration of highly skilled workers.Innovation Networks, Innovation Offshoring, Asia

Sending Jobs Overseas: The Cost to America’s Economy and Working Families

[Excerpt] This report was created by Working America and the AFL-CIO as a companion piece to Work­ing America’s Job Tracker, a ZIP code –searchable database of jobs exported (as well as Occupational Safety and Health Act violations and other work­place issues). Users can search their area for com­panies that have sent jobs overseas. Though Job Tracker is one of the largest publicly available, fully searchable records of the extent and specifics of outsourcing, it only reveals the tip of the iceberg. This report and Job Tracker contextualize each other—Job Tracker by mapping specific job losses due to outsourcing, the report by taking a broad view of the national-level numbers that are avail­able and offering case studies of key industries

Higher Taxes: More Foreign Investment and Fewer United States Jobs

In 2011 with the unemployment rate in the United States high and the economy in a recession many multinational companies argued for a lowering of the repatriation tax to incentivize them to repatriate their foreign earnings. This caused many experts to evaluate the benefit and cost from the last time the federal government lowered the repatriation tax and discussion of implementing a new tax system.B.A. (Bachelor of Arts

Strategic approach to outsourcing the research and development function

This paper proposes an approach for outsourcing the R&D function. This model is to serve as a strategic approach to outsourcing that considers number of elements with strategic competitive advantage as an ultimate objective. This paper suggest that outsourcing research and development should be planed and conducted from a strategic standpoint and have positive impact on organizational competitive position by incorporating it into the overall strategy of the organization to reduce the number of risks inherited in the outsourcing process, and ultimately, achieve competitive advantage

Outsourcing vs. insourcing. Analiza porównawcza wybranych aspektów organizacyjnych i ekonomicznych

Celem artykułu jest prezentacja koncepcji outsourcingu i insourcingu oraz potencjalnych korzyści o różnorodnym charakterze, wynikających z ich zastosowania przez przedsiębiorstwo. Niniejsze opracowanie przedstawia najważniejsze różnice w aspekcie organizacyjnym i ekonomicznym pomiędzy outsourcingiem i insourcingiem. W artykule stwierdzono, że strategia insourcingu jest jeszcze mało znana wśród menadżerów. Natomiast outsourcing jest stosowany, jako główne koło ratunkowe w obniżeniu kosztów przedsiębiorstwa i możliwości skupienia się na głównej działalności przedsiębiorstwa. Przedsiębiorstwa powinny zastanowić się nad zastosowaniem strategii outsourcingu i insourcingu jednocześnie. Należałoby wybrać takie elementy z tych strategii, dzięki, którym przedsiębiorstwo mogłoby osiągnąć jeszcze większe korzyści

Ethical Consequences: Treatment of Stakeholders in Capitalistic Approach and Cooperative Approach to Business

The study illustrates an interpretive glimpse on ethical concern in business corporations. The challenge towards Capitalistic approach to business has given birth to model called Cooperative approach to business. It has been deeply studied and analysed that both entities incur ethical dilemmas due to their nature of business operations. This paper intends to compare capitalistic approach to business (Microsoft Corporation) with Cooperative approach to business (Mondragon Corporation) to identify the ethical consequences that arise from how each entity treats various stakeholders. In recent chaotic business environment, surprisingly, a massive portion of students and many other target audiences in relation with business studies have been lacking the comparative awareness related to ethical consequences in a business that concerning individual profit maximization and a business that concerning social responsibilities across the borderline. This paper flashed characteristics of both approaches so that it can be addressed easily. Keywords: Business Ethics, Capitalistic Corporation, Cooperative Corporation, Ethical Dilemma, MCC

The impact of business outsourcing on corporate real estate in India

Driven by Western companies\u27 requirements for efficiency and effectiveness, a trend towards outsourcing of business activities to India and other low-cost countries commenced in the early 1990s and has continued to grow at a surprisingly fast pace. In a relatively short timeframe India has become a global hub for back-office services, although the effect on the urban cities is yet to be fully comprehended. As American and European companies continue to relocate their information technology services and other back office works to the subcontinent, there has been a considerable flow-on effect on Indian corporate real estate. This paper addresses two key questions. Firstly, the factors important for Western companies\u27 outsourcing of organisational activities to India, and secondly, the effect of business outsourcing on corporate real estate locational requirements in India. A survey of corporate real estate representatives in India and the UK was conducted with the results providing an insight into the present state and possible future direction of outsourcing for India. This research presents a unique insight into the impacts of Western business outsourcing on corporate real estate in India, and presents findings that are useful to both organisations seeking to relocate business activities to India and for property market analysts looking to understand drivers behind this sustained demand for Indian corporate real estate