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Is Incorporation the Solution to the Enigma of Corporate Tax Residency for International Tax Purposes?

Lincoln, Charles Edward Andrew, IV
Texas A&M Law Scholarship · Papers
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business-organizations-lawcorporateincorporationtaxtax-avoidancetax-law
Incorporation of a company for testing residency—if applied uniformly—is likely the best and most accurate way to reflect corporate residency for tax purposes. However, it does not always reflect economic reality. There is not a consensus on what the best approach is. The Organization for Economic C
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