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Corporate America "earns" more money in the Caymans than in Canada (or China). More in the Barbados than Brazil More in the Isle of Man than in Italy Almost as much in Gibraltar as in Germany And more in Luxembourg than in France, Germany, Italy and Spain combined … 1/xpic.twitter.com/cXPFDaPf8U
The 2017 IRS data really paints a remarkable picture. About a quarter (a bit more actually) of the total profits of U.S. firms are reported in low-tax jurisdictions (I assume stateless income is in a low tax jurisdiction) https://www.irs.gov/statistics/soi-tax-stats-country-by-country-report … 2/xpic.twitter.com/GZR2SOzv66
But for the taxes paid to settle "deferment" (so called "deemed repatriation at 15.5%) in 2017 (and now the GILTI) it appears US firms would have paid a very low effective tax rate on profits shifted to low tax jurisdictions. 3/xpic.twitter.com/fliaD7amjM
We don't have the 2018 data yet (lags here are long, two years), but judging from the balance of payments data it doesn't seem like the tax reform changed this much. Apple hasn't changed its tax structure. Microsoft has consolidated its global operations in Ireland ... 4/x
Big pharma companies are still producing the active ingredients in Ireland, Switzerland and Singapore for sale back to the US (wonder why ... ) 5/x
And to the extent there has been evolution (Google looks to have unwound the bulk of its Irish-Dutch-Bermuda tax structure) it is because the US engaged in overt tax competition with a special low 13.125% rate on "intangible income" 6/x
No doubt this will be a big topic of discussion of Davos ... after all, one of the most obvious consequences of globalization as it has been practiced has been the migration of firms profits to low tax jurisdictions 7/7
I've read that when Microsoft sells a copy of Windows or Office in Japan the profit is "earned" in Singapore. 
used to be -- shifted to Ireland in q2 of last year. big tax transaction that distorted the EA/ Irish data
Interesting. Is it certain that profits reported in the CbCR tables do not include dividends? I was only able to find equivalent statements for revenue, but not for profits.
my assumption is that the income/ profits column would be both reinvested earnings and dividends, and that the "accumulated earnings" column would be something like your tax deferral (e.g. current and past reinvested earnings)
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