The Coca-Cola Company, and Includible Subsidiaries - Page 35

                                       - 35 -                                         
          Thus, the current version of the investment incentive takes the             
          form of a tax credit rather than an exemption.                              
               It is clear from the legislative record that Congress was              
          aware of the highly favorable tax benefits afforded U.S.                    
          corporations operating in Puerto Rico.  It is equally clear that            
          Congress intended to retain and reaffirm such tax benefits by               
          enacting section 936.  The Senate Finance Committee and the House           
          of Representatives Committee on Ways and Means stated the                   
          following, in virtually identical reports:                                  
                    The special exemption provided (under sec. 931)                   
               in conjunction with investment incentive programs                      
               established by possessions of the United States,                       
               especially the Commonwealth of Puerto Rico, have been                  
               used as an inducement to U.S. corporate investment in                  
               active trades and businesses in Puerto Rico and the                    
               possessions.  Under these investment programs little or                
               no tax is paid to the possessions for a period as long                 
               as 10 to 15 years and no tax is paid to the United                     
               States as long as no dividends are paid to the parent                  
               corporation.                                                           
                    Because no current U.S. tax is imposed on the                     
               earnings if they are not repatriated, the amount of                    
               income which accumulates over the years from these                     
               business activities can be substantial.  The amounts                   
               which may be allowed to accumulate are often beyond                    
               what can be profitably invested within the possession                  
               where the business is conducted.  As a result,                         
               corporations generally invest this income in other                     
               possessions or in foreign countries either directly or                 
               through possessions banks or other financial                           
               institutions.  In this way possessions corporations not                
               only avoid U.S. tax on their earnings from  businesses                 
               conducted in a possession, but also avoid U.S. tax on                  
               the income obtained from reinvesting their business                    
               earnings abroad.                                                       
                                                                                     
                    The committee after studying the problem                          
               concluded that it is inappropriate to disturb the                      
               existing relationship between the possessions                          




Page:  Previous  25  26  27  28  29  30  31  32  33  34  35  36  37  38  39  40  41  42  43  44  Next

Last modified: May 25, 2011