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Reviewer: Shushugah ( talk · contribs) 20:47, 18 December 2021 (UTC)
Hey Mhawk10 I was looking for more sources about "Pseudo-reorganization acquisitions" but could only find papers by Harris/Brien who coin the article title's phrase/term in 2017 (which you linked in article), [1] and a follow up critique of their paper by Chen/Shevlin. [2]
Here is a summary of subsequent sources used next to the phrase pseudo-reorganization acquisitions
1. In short, my concern is that the article title at very minimum is giving the impression that more than one of the sixteen sources enclosed establish or build on a theory of "pseudo organizational acquisition". This needs to be addressed first, otherwise it's synthesizing the other sources. At worst, this article fails WP:Notability but I wanted to give you a chance to respond first.
2. This article still has a lot of WP:OVERCITE despite feedback about it from a prior peer review and it's not easy to verify what claim is being made from which source.
3. Have a look at an article like Double Irish arrangement for a more abstract/high level overview of tax avoidance practices. This article goes too in depth into IRS laws and specific examples, without giving a scope of how prominent/serious this problem is. For example this article [5] (not included yet) indicates that tax avoidance through acquisition (also a possible alternative Article name) has an effective tax rate reduction of 3%.
If there is no further changes or response, I'll close this GAN as failed this time. Additionally I'd either boldly rename this, or nominate it for deletion, absent 3 independent sources ~ 🦝 Shushugah (he/him • talk) 20:47, 18 December 2021 (UTC)
To be honest, the reason I had chosen this title is because that is the way that I was taught to refer to the clever use of the corporate acquisitions to avoid U.S. repatriation taxes as an undergrad owing to three specific IRS quirks in the IRS code. There’s definitely significant coverage of that topic as a whole here (several articles cover the Killer B, Deadly D, and Outbound F tax avoidance schemes as a part of the same repatriation-tax-avoidance-by-acquisitions phenomenon), though the term “pseudo-reorganization acquisition” does appear to have more limited use in literature. Papers that discuss this include see the paragraph spanning pages 8 and 9 here, several pages in the section on repatriation limitation here, and a lare portion beginning on page 3 of another paper. Yet another paper makes passing reference to the Killer B, Deadly D, and Outbound F as being well-known “contraptions” used to avoid repatriation taxes. My intent in writing this article was to summarize the extant sources that both describe these particular sorts of repatriation tax avoidance behaviors and treat them as a related to some common phenomenon.
I think the current title generally works as a descriptive title for this topic, though if you would like to move this page to “Repatriation tax avoidance via reorganization acquisitions” I would not object except with respect to the title not being concise. I am also unable to access the sciencedirect article, since I am not affiliated with any University anymore and it is not in The Wikipedia Library.
On mobile, so I apologize for the ugliness of the formatting. — Mhawk10 ( talk) 22:14, 18 December 2021 (UTC)
- everyone happy if I pick up the review at /GA2? Best Wishes, Lee Vilenski ( talk • contribs) 15:04, 22 February 2022 (UTC)
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Reviewer: Shushugah ( talk · contribs) 20:47, 18 December 2021 (UTC)
Hey Mhawk10 I was looking for more sources about "Pseudo-reorganization acquisitions" but could only find papers by Harris/Brien who coin the article title's phrase/term in 2017 (which you linked in article), [1] and a follow up critique of their paper by Chen/Shevlin. [2]
Here is a summary of subsequent sources used next to the phrase pseudo-reorganization acquisitions
1. In short, my concern is that the article title at very minimum is giving the impression that more than one of the sixteen sources enclosed establish or build on a theory of "pseudo organizational acquisition". This needs to be addressed first, otherwise it's synthesizing the other sources. At worst, this article fails WP:Notability but I wanted to give you a chance to respond first.
2. This article still has a lot of WP:OVERCITE despite feedback about it from a prior peer review and it's not easy to verify what claim is being made from which source.
3. Have a look at an article like Double Irish arrangement for a more abstract/high level overview of tax avoidance practices. This article goes too in depth into IRS laws and specific examples, without giving a scope of how prominent/serious this problem is. For example this article [5] (not included yet) indicates that tax avoidance through acquisition (also a possible alternative Article name) has an effective tax rate reduction of 3%.
If there is no further changes or response, I'll close this GAN as failed this time. Additionally I'd either boldly rename this, or nominate it for deletion, absent 3 independent sources ~ 🦝 Shushugah (he/him • talk) 20:47, 18 December 2021 (UTC)
To be honest, the reason I had chosen this title is because that is the way that I was taught to refer to the clever use of the corporate acquisitions to avoid U.S. repatriation taxes as an undergrad owing to three specific IRS quirks in the IRS code. There’s definitely significant coverage of that topic as a whole here (several articles cover the Killer B, Deadly D, and Outbound F tax avoidance schemes as a part of the same repatriation-tax-avoidance-by-acquisitions phenomenon), though the term “pseudo-reorganization acquisition” does appear to have more limited use in literature. Papers that discuss this include see the paragraph spanning pages 8 and 9 here, several pages in the section on repatriation limitation here, and a lare portion beginning on page 3 of another paper. Yet another paper makes passing reference to the Killer B, Deadly D, and Outbound F as being well-known “contraptions” used to avoid repatriation taxes. My intent in writing this article was to summarize the extant sources that both describe these particular sorts of repatriation tax avoidance behaviors and treat them as a related to some common phenomenon.
I think the current title generally works as a descriptive title for this topic, though if you would like to move this page to “Repatriation tax avoidance via reorganization acquisitions” I would not object except with respect to the title not being concise. I am also unable to access the sciencedirect article, since I am not affiliated with any University anymore and it is not in The Wikipedia Library.
On mobile, so I apologize for the ugliness of the formatting. — Mhawk10 ( talk) 22:14, 18 December 2021 (UTC)
- everyone happy if I pick up the review at /GA2? Best Wishes, Lee Vilenski ( talk • contribs) 15:04, 22 February 2022 (UTC)
References
{{
cite journal}}
: Cite journal requires |journal=
(
help)
{{
cite journal}}
: Cite journal requires |journal=
(
help)
{{
cite journal}}
: Cite journal requires |journal=
(
help)
{{
cite journal}}
: Cite journal requires |journal=
(
help)
{{
cite journal}}
: Check date values in: |date=
(
help)
{{
cite journal}}
: Cite journal requires |journal=
(
help)