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The home company thus pays royalties to its Irish subsidiary on sales of the drug in the United States, transferring profits from the United States to Ireland.
Such losses could be large enough to prevent the Fed from transferring profits to the Treasury Department for the first time since 1934, according to a Fed analysis.
There were also more attacks on big companies' use of the international tax system, with many multinationals seeing huge reductions in their tax bills by transferring profits to countries with a more favourable tax rate.
Two have applied, but so far neither has achieved the upgrade.Raimondo Eggink, a Dutchman, led the first legal challenge by minority shareholders in Poland, against Michelin of France for unfairly transferring profits from its listed local subsidiary, Stomil Olsztyn.
Revenue and Customs, the British tax agency, changed its rules on transferring profits across borders last year, to ensure "consistency for businesses" and to focus on the "issues of greatest risk," a spokesman said.
The accounting firm Ernst & Young estimates that since 2006, at least 10 jurisdictions have introduced tougher requirements on transferring profits across borders, with China, Slovakia and Greece among the most recent.
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Selling the securities at a loss would reduce the Fed's ability to transfer profits to the Treasury Department.
Firms also use such wheezes to transfer profits to affiliated firms in low-tax areas, such as Hong Kong.
Others with strong monopolies have transferred profits from their protected letters franchises to battle in the more competitive parcels business.
It would repeal rules that make it harder for American companies to transfer profits across borders without having to pay taxes.
The United States does not tax sales made by those subsidiaries, nor does it impose duties when they transfer profits to their parent companies.
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