Per the text, a U.S. parent company doesn't include the income of the foreign subsidiary till the income is repatriated as dividends. Defend the creation of foreign subsidiaries as a mechanism to defer income of major U.S. companies. Propose a new tax law that will benefit the U.S. Treasury from the deferral of income from foreign subsidiaries and encourage the repatriation of the previously deferred income.
Examine the current provisions of the IRC designed to prevent tax avoidance between a U.S. corporation and a foreign subsidiary, and evaluate the importance of using advance pricing agreements (APAs) to execute such provisions. Defend or critique the confidentiality treatment of APAs under the Freedom of Information Act (FOIA). Justify your position.