Last week, federal law enforcement officials executed a high profile raid of Caterpillar to investigate accusations of international tax fraud. Regardless of the merits of the case against Caterpillar, the raid may have been meant to send a broader message to multinational companies that the United States will scrutinize strategies to shift income to lower tax jurisdictions.
The IRS has announced thirteen areas of focus in tax audits, including companies with significant offshore earnings.
There is hope for tax reform that will attract global investment in the United States by reducing tax rates and adopting a territorial tax system rather than a global tax system. But, in the meantime, it seems that the administration is creating a chilling effect on US companies earning income overseas.