Sample Essay

The US government seems to be targeting two types of transactions. It seems most concerned with corporate tax shelters that threaten the domestic tax base i.e. the taxable revenue stream from domestic activities of its domestic taxpayers. Many of these transactions create something out of nothing. Some result in income simply not being taxed to domestic taxpayers that economically earn the income; others create deductions or losses that shelter what is otherwise taxable income of domestic taxpayers.

Because of the broader marketing presence of tax professionals in promoting these types of transactions, the lawmakers and tax authorities continue to respond in a cat-and-mouse fashion. Analysis of Strengths, Weaknesses, Opportunities, Threats, and Trends is the most accurate, efficient and cost-effective way to get a solid understanding of a business. The first key to a good SWOTT is to ask the right questions, and good judgment is required in synthesising information to developing the Strengths, Weaknesses, Opportunities, Threats, and Trends in Economy of Business in the United States of America. The US government’s concern on international tax arbitrage underlies its efforts to reverse course in permitting taxpayers to elect hybrid treatment of entities. The US government apparently does not wish to tolerate the use of hybrid entities to reduce the foreign tax burden on income from foreign business operations of US multinationals if it means that the income will not be taxed in the US.

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