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Re: io_io post# 12288

Saturday, 06/18/2005 10:02:58 PM

Saturday, June 18, 2005 10:02:58 PM

Post# of 257287
Re: big-pharma repatriation

The exact rules are spelled out in a U.S. Treasury document that I haven’t read. However, the basic skeleton has been laid in the business press. The main points are:

1. The federal tax rate on repatriated earnings is reduced by 85% (from 35% to 5.25%) in 2005 only.

2. Companies wishing to take advantage of this 85% reduction must submit a written plan to the IRS explaining what the repatriated money subject to the exemption will be used for.

3. In general, use of the repatriated money for acquisitions will qualify for exemption.

4. Among all U.S. industries, Big Pharma has the most money to be repatriated. That’s because a large proportion of BP’s earnings come from overseas, thanks to various tax games they play with transfer payments between multinational subsidiaries for manufacturing and IP licenses.

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There is no question that there will be more large biotech acquisitions during the balance of 2005 and thereafter (if the repatriated funds have not yet been spent).

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