Where Form 8865 Transfers 2023-2024

Let's say that I run a country, or I should say, run a company that is based inside the United States. So, this right over here is my company, and maybe I have some smokestacks. That is my company, and it makes a million dollars in pre-tax profits. This is before tax, so pre-tax profits. Let's say that at the time I make those pre-tax profits, the corporate tax rate is 35%. So, it's pretty straightforward to think about how much taxes I would have to pay. I would pay 35% on this 1 million dollars, or essentially I would pay three hundred fifty thousand dollars in taxes, and I would have six hundred fifty thousand left in profit. Now, let's say my company wants to get a little bit more creative about how it might save on taxes. It realizes that there's an island not too far off the US coast with a substantially lower tax rate. Let's say it has a five percent corporate tax rate. So, how can this company, which is based in this country, benefit from this lower tax rate that is happening offshore? Well, what they'll typically do is set up another subsidiary, one that this company owns and controls but is set up in this little island nation. So, they'll give it some intellectual property, like patents or trademarks, so it gets all of the intellectual property of the parent company. This subsidiary is owned and controlled by the parent entity based in the US. What they'll say is, "Look, we don't have a million-dollar pre-tax profit anymore because we essentially need to license the use of this intellectual property. We have to pay this entity here some amount of money to use that intellectual property." Let's say they decide to pay them eight hundred...