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One reason corporations are so diligent about avoiding taxes is scale. If you can save, say $1 million, byt paying lawyers & accountants $500,000, the decision is a no-brainer. I'm sure this is exactly how Apple's outside counsel sells it.

I think the best approach is just to eliminate corporate taxes. If instead you just tax the dividends, that same $1,000,000 in liability will be distributed among thousands of shareholders, who will not have nearly as strong an incentive to hire $400/hour lawyers.



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