David S. Miller (Cadwalader, New York) has published How U.S. Tax Law Encourages Investment Through Tax Havens, 131 Tax Notes 167 (Apr. 11, 2011):
In this report, he catalogues the many ways that federal and state tax law encourages taxpayers to operate through foreign tax haven companies to reduce their federal and state tax liabilities, and he suggests some changes to the law that would eliminate these incentives.
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