Suchergebnisse

This paper was accepted for publication in the journal International Politics and the definitive published version is available at https://doi.org/10.1057/s41311-017-0125-x ; © 2017 Macmillan Publishers Ltd., part of Springer Nature The point of departure for the special collection is provided by the observation that the growing complexity of the crises in the neighbourhood and the internal ones faced by the Union provides a sense of urgency to any type of strategic thinking that the EU might embrace. Against this backdrop, the recent shift towards geopolitics and strategic thinking is contextualized and the understanding of key aspects of ways in which the shift is translated into strategies by EU actors is put forward. The analysis recognizes the recent developments within the institutional dimension of EU's foreign and security policy, yet it confirms the fundamental meaning of the member states' willingness to invest resources and harmonize their foreign policy strategies at the EU level.

ABSTRACT
The high corporate tax rate and the complexity of the U.S. tax code provide U.S. multinationals with the incentives and opportunities to shift income to foreign low-tax jurisdictions. In theory, U.S. corporations are taxed at the statutory rate of 35 percent on their worldwide income, but income earned by an active Controlled Foreign Corporation (CFC) is usually not taxed until it is repatriated to the parent company in the U.S. As a result, trillions of dollars in cash and investments sit in offshore companies, awaiting a repatriation tax holiday. Much of these earnings are held by technology companies. The case looks at Microsoft Corporation, a company with $60.8 billion in unrepatriated earnings as of 2012. The case considers tax havens, nonrepatriation of earnings, cost-sharing arrangements, and transfer pricing and is intended to expose students to the subtleties and complexities of corporate tax strategies. Although the case is set in 2012, the goal of the case is to demonstrate to the students the complex environment in which multinational corporations operate and is independent of any particular tax regime.

Remarks by President Bush and Senator Kerry, October 1, 2004