structural:expansion
Unitary groups

Approaching 30 years since the 1984 principals of the Worldwide Unitary Tax Working Group, it is questionable whether or not a competitive balance for U.S. multinationals, foreign multinationals, and purely domestic businesses has been attained. Bloomberg reporter Jesse Drucker demonstrates that separate accounting/arm's length pricing favors the multinationals in an October 2010 article titled "Google 2.4% Rate Shows How $60 Billion Lost to Loopholes" with tax strategies known as the "Double Irish" and the "Dutch Sandwich." In a New York Times October 2012 Dealbook column, Victor Fleischer wrote about "Overseas Cash And The Tax Games Multinationals Play." Although billions in corporate profits are reported to be on the books of foreign subsidiaries located in tax havens, a New York Times article by David Kocieniewski titled "For U.S. Companies, Money Offshore Mean Manhattan" dated May 2013, indicates that those corporate profits are being utilized in the U.S. This is supported by a more recent report by Kitty Richards and John Craig at the Center for American Progress titled "Offshore Corporate Profits - The Only Thing 'Trapped' is Tax Revenue" An article by Floyd Norris in the May 23, 2013 New York Times, "The Corrosive Effect of Apple's Tax Avoidance", points out how these tax avoidance strategies will most likely be followed by many other multinational corporations. And, an article by David Gelles titled "New Corporate Shelter: A Merger Abroad" dated October 8, 2013 makes a case that the best tax strategy for a U.S. based corporation is to become a foreign based corporation.