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Re:Microsoft Irish subsidiary paid zero corporate tax on £22... by fallingknife on Thursday June 03, 2021 @09:45AM (#27381236)
$100 -> corp. $90 -> expenses, $10 -> profit. $4 -> corp tax, $6 -> shareholders dist.

$100 -> corp. $90 -> expenses, $10 -> profit -> shareholders dist. $4 -> personal income tax.

In principal it's the same. Path 1 is easier to dodge, because what constitutes "expenses" is hard to define, but distributions are obvious. And the numbers don't have to add to 100. So reality looks more like:

$100 -> corp. $95 -> "expenses", $5 -> "profit". $2 -> corp tax, $8 -> shareholders dist.

vs

$100 -> corp. $95 -> "expenses", $5 -> "profit". $10 shareholders dist. $4 -> personal income tax.

And this is why you want to tax at the distribution level.

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