Talk:Repatriation tax avoidance/GA1

GA Review

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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), and a follow up critique of their paper by Chen/Shevlin.

Here is a summary of subsequent sources used next to the phrase pseudo-reorganization acquisitions

• Bloomberg: No mention of pseudo. Does mention Killer D/Deadly B IRS tax reorganization practices
• No mention of pseudo except for "Pseudo R squared" label on p48-49,56.
• No mention of pseudo here either; does discuss reorganizations.

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 (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)

• 2nd opinion, got here from GA talk page. Although it's great to see more writing on taxation, which is definitely underrepresented on Wikipedia, I think the review above has valid concerns when it comes to the article's scope/title, reference issues and possible gaps in coverage. (t · c) buidhe 21:03, 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)

Additionally, if the above satisfies your notability concerns, are there specific things that you would want to see worked on aside from WP:OVERCITE? I don’t think the article is all that far away from meeting the GA breadth requirement if what is missing is a paragraph or two on how different studies evaluate the traditional effectiveness of the strategies, but I would like pointers as to how to improve this if this is going to fail. — Mhawk10 (talk) 22:18, 18 December 2021 (UTC)

@Mhawk10 thanks for the quick response! As long as you're actively working on it, am happy to pause the review and re-review in a timely fashion. I looked over the three links you sent me and I am summarizing what I took away from them. They're all good sources for sure and should be included in article, but none mention the phrase "pseudo" or "reorganizational" anywhere.

• Yang:
• Loomis: Discusses Killer B, Deadly D and Outbound F. The level of detail it gives to the specific IRS codes they refer is right amount of abstraction. The current Wikipedia article includes excessive legal text, when
• Martin:

Repatriation tax avoidance is the most consistent name I am seeing from all the sources you've mentioned (and in my own research). The style of writing for university where WP:SYNTHESIS and WP:Original research are actively encouraged, is quite different from Wikipedia. I found Wikipedia:Relationships with academic editors a thoughtful essay about that.

Concrete action items from my end:

1. Rename the article to anything authoritatively backed by multiple articles. Could be Repatriation tax avoidance or something else as long as it's not an original/synthesized term.
2. Aim for a maximum of 1-2 citations per statement. If multiple citations are valid, use the best/most insightful one. I will be strict about this, especially given the technical complexity and length of the sources. Would be nice to have specific page numbers, but that's not a requirement so I won't expect that.
3. Delete the entire legal source text of Definition of Reorganizations under Internal Revenue Code Section 368(a)(1). Most of the academic articles manage to explain without listing the text inline over 30 pages. A shorter Wikipedia article that is encyclopedic, should be even more succinct.
4. Subsections A, C and E are not even mentioned in any of the sources provided. The fact that Killer B is a reference to Subsection B, or Deadly D to subsection D is not obvious either.
5. What is the relation to Double Irish arrangement? This topic is very much related, and arguably could be a subsection of that article, but if it will be its own article, it should explain its relation at minimum. Merely linking to Double Irish arrangement is not enough for a Good Article status.
6. A section about the likelihood of mergers/acquisitions is an interesting one. Not necessary, but nice to have.

I won't always be able to write such long/suggestive replies, but was intrigued by this topic and your willingness to work on it further Buidhe feel free to add anything else. Kind regards ~ 🦝 Shushugah (he/him • talk) 23:34, 18 December 2021 (UTC)

@Shushugah: I've moved the page per above. I'm going to get working on the remaining feedback today and over the next week. I'm not going to be editing when it gets closer Christmas, but I can ping you when I believe I've improved the article in line with your feedback above. — Mhawk10 (talk) 18:22, 19 December 2021 (UTC)

@Shushugah and Buidhe: I believe that I've made significant progress on points 1-3 and 5 above, and I'd like feedback to see if this is sufficient. I'm not exactly sure of how to address point 4 except to not reference to subsections A, C, and E. I don't think the article currently does this, so I think that there has been progress made there, as well. — Mhawk10 (talk) 02:01, 28 January 2022 (UTC)

@Shushugah and Buidhe: any updates? — Mhawk10 (talk) 04:30, 22 February 2022 (UTC)

Shushugah has stopped editing, you may need a new reviewer. (t · c) buidhe 04:31, 22 February 2022 (UTC)

- everyone happy if I pick up the review at /GA2? Best Wishes, Lee Vilenski ^{(talk • contribs)} 15:04, 22 February 2022 (UTC)

References