University of Surrey

Test tubes in the lab Research in the ATI Dance Research

Google's "Alphabet Soup" in Delaware

Bogenschneider, B (2016) Google's "Alphabet Soup" in Delaware Houston Journal of Business Law & Taxation, 16. p. 1.

[img] Text
Google's Alphabet Soup in Delaware_16 Houston Bus Tax J 1 (2016) lead.pdf - Version of Record
Restricted to Repository staff only
Available under License : See the attached licence file.

Download (622kB)
[img] PDF (licence)
SRI_deposit_agreement.pdf
Restricted to Repository staff only
Available under License : See the attached licence file.

Download (33kB)

Abstract

In this article the tax avoidance planning of Google’s “Alphabet” Delaware reorganization is explored in detail. The recent Google reorganization created an IP parent holding company in Delaware (“Alphabet”) yielding potential state corporate income tax avoidance benefits, including: (1) incremental royalty expense deductions in non-combined reporting states; (2) potential exclusion of foreign royalty income from the tax base in combined reporting states; (3) creation of a constitutional challenge to the taxation of foreign royalty income of Alphabet; and (4) domestic IP license benchmark for foreign affiliates to allow for repatriation of offshore cash by higher royalty payments. The article suggests that U.S. states are not obliged to follow a formalistic method of legal interpretation of tax transactions that lack economic substance (i.e., to recognize the Alphabet reorganization), and further addresses Google’s corporate slogan “don’t be evil” in light of its aggressive federal and state tax avoidance behavior.

Item Type: Article
Authors :
AuthorsEmailORCID
Bogenschneider, BUNSPECIFIEDUNSPECIFIED
Date : 25 August 2016
Depositing User : Symplectic Elements
Date Deposited : 28 Mar 2017 11:00
Last Modified : 28 Mar 2017 11:00
URI: http://epubs.surrey.ac.uk/id/eprint/811839

Actions (login required)

View Item View Item

Downloads

Downloads per month over past year


Information about this web site

© The University of Surrey, Guildford, Surrey, GU2 7XH, United Kingdom.
+44 (0)1483 300800