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More than $2 trillion of foreign profits generated by American multinationals is purposefully locked out of the United States in order to avoid U.S. taxation upon repatriation and to benefit from the deferral rule of the U.S. Internal Revenue Code, which allows U.S. corporations with controlled foreign corporations (CFCs) to defer taxation of the foreign-sourced active income of the CFC subsidiary until it is repatriated through dividend distributions to the U.S. parent company. Severaldoi:10.7916/cjtl.v8i2.2841 fatcat:tqtfmlf3ufecvelyclx3lqhi6y