FACTBOX: Republicans cut side deals to push through US Senate tax bill

WASHINGTON -- US Senate Republicans made last-minute changes to their tax bill to secure enough votes to pass the sweeping legislation on Saturday and move on to negotiations this week on a final measure with Republicans in the House of Representatives.

The deals enabled leadership to get 4 wavering Republican senators on board with the legislation by addressing issues such as deductions for state and local property taxes and the tax treatment of so-called pass-through enterprises.

Republicans also agreed to changes to help pay for the deals, including higher tax rates on the repatriation of US corporate profits held overseas.

Following are some of the changes:

* STATE AND LOCAL PROPERTY TAXES: Senator Susan Collins got Senate Republican leaders to include a federal deduction for up to $10,000 in state and local property taxes in the legislation, which eliminates a similar deduction for state and local income and sales taxes.

The nonpartisan Joint Committee on Taxation, or JCT, estimates that the change will mean the loss of an additional $148 billion in federal revenue over the next decade, compared with a legislative proposal approved earlier by the Senate Budget Committee.

* PASS-THROUGHS: Under pressure from Senators Ron Johnson and Steve Daines, Senate Republican leaders increased to 23 percent from 17.4 percent a deduction for the owners of pass-through enterprises including small businesses, S-corporations, partnerships and sole proprietorships.

JCT estimated revenue loss versus earlier legislative proposal: $114 billion.

* FULL EXPENSING: Senator Jeff Flake, who had been a holdout over deficit concerns, agreed to vote "yes" after Republican leaders did away with an abrupt end to the full business expensing of capital investments after five years. Instead, the bill phases out full expensing in 20 percent increments over 4 years, beginning in year 6. Flake said Congress would not have been able to suddenly eliminate full expensing and that benefit would have been left to bleed red ink for years to come.

JCT revenue loss estimate versus earlier legislative proposal: $34 billion.

* MEDICAL EXPENSES: Collins also added language to reduce the threshold for deducting unreimbursed medical expenses for 2 years to 7.5 percent of household income from 10 percent.

JCT estimated revenue loss versus earlier legislative proposal: $4.6 billion.

* RETIREMENT SAVINGS: Collins persuaded Republican leaders to retain catch-up contributions to retirement accounts for church, charity, school and public employees.

No immediate JCT revenue impact estimate.

* INDIVIDUAL ALTERNATIVE MINIMUM TAX: Republicans rescinded an earlier provision to repeal the individual AMT but increased exemption amounts and phase-out thresholds to make the tax less onerous.

JCT estimated revenue gain versus earlier legislative proposal: $133 billion over a decade.

* REPATRIATION: Senate Republicans increased tax rates on the repatriation of US corporate profits held overseas to 14.5 percent for liquid assets and 7.5 percent for illiquid holdings, up from 10 percent and 5 percent, respectively.

JCT estimated revenue gain versus earlier legislative proposal: $113 billion.

* CORPORATE ALTERNATIVE MINIMUM TAX: Republicans decided to retain this tax, after initially proposing its repeal.

JCT estimated revenue gain versus earlier legislative proposal: $40.3 billion.

source: news.abs-cbn.com

After hot debate, US tax bill a boon to businesses

WASHINGTON - Is it a giveaway to the rich or a relief for the middle class? A boon for business or unnecessary stimulus for an economy already at full employment?

The sweeping tax reform package adopted by a slim margin of 51-49 early Saturday by the Republican-controlled Senate has sparked fierce debate among economists.

It also has yet to be reconciled with a separate version passed by the House of Representatives.

But the proposal's main planks included a reduction in corporate tax rates from 35 to 20 percent, increasing some deductions for individual taxpayers while eliminating many others and reducing taxation on partnerships.

The White House portrays the new tax package as the largest tax cut in US history and says it is aimed at spurring growth and producing higher wages and corporate profits while encouraging tax-shy companies to repatriate their wealth.

One of the proposal's main boosters, Treasury Secretary Steven Mnuchin, recently touted a letter from nine economists who asserted that the first comprehensive tax overhaul in three decades would lift annual GDP growth by 0.3 percent over 10 years.

But a University of Chicago study found that among 38 economists, the overwhelming majority doubt growth will increase and nearly all believed it would balloon the national debt.

The Joint Committee on Taxation, a nonpartisan committee which estimates the cost of tax policies, also found Thursday the bill now passed by the Senate would add $1 trillion to the deficit.

Many economists argue that this kind of stimulus has limited impact when the economy is growing at its full potential pace.

Disagreements have at times turned personal, with former Labor Secretary Robert Reich, a Democrat, writing in an opinion piece on Wednesday that Mnuchin was either a "fool or a knave," accusing him of lying about the supposed benefits of the tax overhaul.

IS NOW THE RIGHT TIME?

Reich cited the findings of the Tax Policy Center, according to which over a decade most of the proposal's benefits are likely to go to the wealthiest one percent of Americans while the upper middle class would likely face a higher tax burden and the poorest would see only small tax cuts.

But according to Douglas Holtz-Eakin, one of the economists who signed the letter cited by Mnuchin, said the modified new tax code aims to boost production and supply, rather than demand.

Entrepreneurs are among the first who stand to gain, with corporate tax rates falling as much as 15 percentage points, supposedly down to a level in line with those in other developed countries.

But US companies have long benefitted from tax deductions that brought their effective tax rate down to around 21 percent.

Another boon for the business world: partnerships and other so-called "pass-through" companies whose profits are enjoyed directly by their owners -- and which account for half of corporate revenue and 90 percent of small businesses -- will see steep tax cuts.

Multinational companies also will be encouraged to repatriate their profits at a preferential tax rate.

According to Holtz-Eakin, these changes are all incentives for innovation and investment that will drive productivity in the United States.

However, as White House economic adviser Gary Cohn found while attending a business conference recently, many companies plan to use excess cash from the tax cuts to increase their dividend rather than invest in equipment or hire more workers.

President Donald Trump's administration argues that wages should rise after having stagnated for decades when accounting for inflation.

Holtz-Eakin said productivity gains should make hiring workers more profitable and cause companies to compete for available labor by offering higher salaries.

Others call the timing of such a tax overhaul into question, given that the world's largest economy is already close to full employment and the Federal Reserve is poised to pounce on any sign of inflation by raising interest rates.

Lloyd Blankfein, the CEO of Goldman Sachs, expressed similar doubts last month in an interview with Bloomberg.

"I can't say this is the moment where you want the most fiscal stimulus in the market, when we’re mostly at full employment, when GDP last registered at 3 percent," he said.

"I don’t know that this is the moment that you provide the biggest stimulus."

source: news.abs-cbn.com

Burger King has maneuvered to cut US tax bill for years

Burger King may have taken a lot of flack in the past week for a deal that should curb its U.S. tax bill but in many ways it is consistent with the burger chain's aggressive tax-reduction strategies in recent years.

Some U.S. lawmakers and other critics attacked the company that is the home of the Whopper for deciding to move its tax base to Canada from the U.S. through its proposed purchase of Oakville, Ontario-based coffee and doughnut chain Tim Hortons . They say it will allow Burger King to avoid paying some U.S. taxes.

That would be nothing new. A Reuters analysis of Burger King's regulatory filings in the U.S. and overseas, which was also reviewed by accounting experts, shows that it has been making major efforts to reduce its U.S. tax bill for some time.

By massaging down U.S. taxable profits while maximizing the profits it reports in low-tax jurisdictions overseas, Burger King is able to operate one of the most tax-efficient businesses in the U.S. fast-food industry.

The chain's effective tax rate of 26 percent over the past three years compares with rates above 31 percent at McDonalds Corp, Starbucks Corp and Dunkin Brands Group Inc. KFC and Pizza Hut owner Yum Brands did have a similar tax rate to Burger King though this reflects the 74 pct of its revenues that were generated outside the U.S., in markets where tax rates are typically around 25 percent.

The Burger King rate is 30 percent lower than the average tax rate it paid in the five years before it was bought in 2010 by private equity group 3G, still the company's majority shareholder.

The accounting experts say the Canadian move will allow Burger King to double-down on those efforts as it will open up new tax-saving opportunities for the company. It could, for example, apply the tax structures it currently employs in major markets like Germany and Britain, and which allow the group to operate almost tax free in those places, to its business in the United States, they said.

And that could mean Uncle Sam will lose corporate tax income that Burger King would have to pay under its current structure.

"I would be surprised if in five years' time, their tax rate does not come down reasonably dramatically," said Professor Stephen Shay, from Harvard Law School, who has testified to Congress on corporate taxation.

Burger King declined to comment on its current U.S. tax arrangements. But it has said the so-called "inversion" deal to buy Tim Hortons for $11.5 billion, and move the headquarters to Canada, was based on Canada being the combined company's biggest market. It said the deal was about international expansion - particularly of the Tim Hortons' brand and not about tax savings.

"We don't expect our tax rate to change materially. As I said this transaction is not really about tax, it's about growth," Chief Executive Daniel Schwartz said in a call with analysts last week.

It would be perfectly legal for Burger King to reduce its U.S. tax bill through the Canadian move. Chas Roy-Chowdhury, Head of Taxation at the Association of Chartered Certified Accountants in London, said companies all over the world manage their tax bills so they don't have to pay more tax than necessary.

"If the U.S. doesn't like inversion deals, it should change the law to prevent them. The U.S. has a leaky corporation tax system which encourages companies to park profits offshore," he said.

U.S. MARGINS LOW

Finding ways to report less income to the Internal Revenue Service (IRS) and more to overseas tax authorities is a particular focus for companies with a headquarters or big operations in the U.S. because of the headline federal corporate tax rate of 35 percent on profits. It is the highest headline corporate tax rate in any major developed country, and can be even higher once state and local taxes are added on. There is an incentive for companies to shift U.S.-generated profits overseas, where rates can be very low, the experts say.

Burger King generated almost 60 percent of its revenues in the United States between 2011 and 2013, regulatory filings show, but the chain reported just 20 percent of its profits in the country over the period.

By contrast, the percentage of their profits that McDonalds, Starbucks Corp, Dunkin Brands and Yum reported as being earned in the United States was in line with the percentage of their total revenues generated in the country.

Those companies all declined to comment.

Shay said Burger King's large debt load could explain why it has more ability to manage its U.S. tax bill than less leveraged peers.

Burger King's low reported U.S. profit translates to domestic profit margins of just an average 4 percent between 2011-2013 - a fifth of the level it recorded in overseas markets in that time. The company declined to say why its U.S. operation enjoyed such low margins over the period - it reported a small U.S. loss in 2012 and a tiny profit for 2011, though the profit was up to a much healthier level by 2013.

There could be explanations other than tax-driven moves for the low margins. The U.S. fast food market is the most competitive in the world, and prices for fast food offerings are lower than in some other major markets as a result. However, a lot of the burden, including increased labor costs as the minimum wages rises in some states and spending on a refurbishment program for Burger King restaurants, would be borne by the company's franchisees. Burger King operates very few of its own restaurants.

Professor Daniel Shaviro from New York University Law School, who was previously Legislation Attorney at the Joint Congressional Committee on Taxation, said tax planning likely had a lot to do with the low levels of income reported in the U.S.

The company's accounts show the low reported U.S margins are due, at least in part, to how hundreds of millions of dollars in group overheads, such as head office and debt costs are spread across the company each year.

Before such costs are applied, profit margins at Burger King's United States and Canada division (the U.S. produces 91 percent of that unit's revenue) are in line with international operations, at around 39 percent, its filings show. But after these costs are applied, the North American unit ends up with its rock-bottom margins.

Most of these costs are taken in the U.S. because it is where cash is borrowed, and senior managers and product innovators are based. But tax rules state that such costs should be evenly spread across international divisions, said Kimberly Clausing, a Professor of Economics at Reed University.

Clausing said the gap between Burger King's gross and pre-tax profit figures for the United States suggested such group-wide costs are being disproportionately offset against U.S. income.

"That's one way of shifting income abroad ... it's a common problem," for the IRS, said Clausing.

TAX FREE IN GERMANY

Burger King also operates a tax-efficient operation overseas. By channeling income through Switzerland it has managed to pay an effective tax rate of 15 percent on foreign income over the past three years, company filings and statements show.

Experts said this arrangement could become a template for how Burger King, as a foreign company, could shave its U.S. tax rate further.

The impact in Germany shows how that could cost the U.S. Treasury.

Germany has historically been Burger King's largest market outside North America, generating over 10 percent of total sales. In 2011 and 2012, the last two years for which figures were available, the German operation had combined sales of $501 million - over half the total for the Europe, Middle East and Africa region, regulatory filings show.

In 10 conference calls with analysts covering the two-year period, transcripts of which Reuters reviewed, then-Chief Financial Officer Schwartz mentioned the German market eight times, and each time spoke of its "strong performance" or "positive" results.

EMEA operating profits for 2011 and 2012 totaled $356 million. Yet, Burger King Beteilligung GmbH - the entity which consolidated earnings for the group's main German operating units - reported losses in 2011 and 2012, totaling over $10 million and recorded a net income tax credit of more than 200,000 euros.

Burger King Germany's taxable income was reduced partly because German stores pay around five percent of their turnover to an affiliate in Switzerland, Burger King Europe GmbH, the company told Reuters in 2012.

Burger King Europe GmbH owns brand rights for Europe, the Middle East and Africa - which also allows profits from other places, not just Germany, to be at least partly funneled through Switzerland.

Burger King declined to say why the group declared no profits in Germany at the same time as it boasted to investors about the market's strength, but a spokeswoman said the tax structure in Europe pre-dated New-York based 3G's acquisition of the chain in 2010.

Almost all of Burger King's restaurants are now run on a franchise basis rather than directly by the company, and more than 80 percent of the company's revenue comes from franchise fees and property revenue. At the end of last year, it had 7,384 franchised restaurants in the U.S. and 52 company owned and run - the latter are in the Miami area near the company's current headquarters so it can test new food offerings and other changes to the way it operates.

Under U.S. tax rules, Burger King cannot currently cut its American tax bill by routing franchise fees from its U.S. franchisees via Switzerland. But these rules would not apply to a Canadian company. The company spokeswoman said Burger King had no plans to shift franchisees into contracts with offshore subsidiaries.

source: www.abs-cbnnews.com

How this German tech giant trims its US tax bill

LONDON - In July 2012, then-U.S. Treasury Secretary Tim Geithner travelled to an island off the German coast to meet Wolfgang Schaeuble, Germany’s finance minister. Schaeuble was on vacation, but Geithner visited to discuss the euro zone crisis. Talk also turned to a long-running bugbear of Schaeuble’s: corporate tax avoidance.

According to a letter Schaeuble later wrote to Geithner, the Treasury Secretary had explained in their conversation that the most aggressive forms of avoidance often involved technology companies parking valuable know-how in low-tax countries and making other parts of the company pay high rates to use it.

In Schaeuble’s letter he sought Geithner’s support for international action against legal tax dodging. Profit shifting, the finance minister said, was largely a problem involving U.S. companies. Tax rules in Germany made it more difficult there. This “could explain why we do not know of German companies with comparable tax arrangements to the U.S. companies,” the letter, seen by Reuters, said.

But an examination of the accounts of one of Germany’s largest firms shows it uses similar techniques. Without them, it would pay more than 100 million euros ($133.53 million) in additional tax each year, some of it to the United States.

SAP AG provides software for businesses to process and analyse transactions, counts 80 percent of the Fortune 500 as customers and has a market capitalisation of $90 billion, making it the fourth biggest firm in Germany. Its accounts show that it – like U.S. tech firms such as Google and Microsoft - channels profit to subsidiaries in Ireland, where the corporate tax rate is 12.5 percent. The comparable rate in Germany is 30 percent and in the United States, SAP’s largest market, 39 percent, according to the Organisation for Economic Cooperation and Development (OECD), an international think tank.

SAP, which is headquartered in Walldorf, Germany, has paid a global annual tax rate in the last three years averaging 26 percent. That’s nearly 20 percentage points less than the company paid a decade earlier.

Like other German companies, SAP has benefited from significant German tax cuts over that time, but it is only taxed on part of its profits in Germany. The company is structured so that Ireland, which accounts for less than 1 percent of its sales and employees, is the home base for 20 percent of its profits. SAP uses Dublin as a base for know-how and other intellectual property generated by staff around the world, and has an Irish subsidiary lend billions of dollars to a U.S. affiliate for much higher interest rates than the group pays on the open market.

There is nothing illegal about this; the company said profits reported in Ireland reflect genuine economic activity and risks borne by Irish subsidiaries, and the structure was driven by operational rather than tax motives. “SAP didn’t come to Ireland for taxes,” Liam Ryan, who heads SAP’s Irish operation, told Reuters at the group’s campus in the leafy Citywest office park on the outskirts of Dublin. “The reason SAP invests here is because we deliver.”

Tax authorities in Germany and the United States declined comment, citing rules on taxpayer confidentiality. A spokesman for Finance Minister Schaeuble said he would not comment on specific companies.

Sven Giegold, a German member of the European Parliament and spokesman on economic affairs with the Green Party, said, “This shows U.S. companies are not alone in engaging in clever tax planning.” He said the arrangements were clearly “contrived... It is obvious that these arrangements are tax motivated. It is not convincing to say otherwise.”

Sahra Wagenknecht, a member of the German parliament and a spokeswoman on economic and tax matters for Die Linke, a left-wing party which calls for higher taxation, said SAP's case highlighted inadequacies in current tax rules that the government should address.

Corporate tax is an increasingly touchy topic as indebted governments cut budgets. Last year, Schaeuble worked with colleagues from France and Britain to launch a major review of international tax rules aimed at ensuring multinationals pay their fair share and at reducing what has become known as "base erosion and profit shifting" (BEPS). Governments aim to agree new rules in a couple of years.

Edward Kleinbard, Professor of Law at the University of Southern California, says U.S. business lobbyists have depicted these efforts at tax reform as anti-competitive, a bid to weaken U.S. firms by having them pay more tax to overseas governments.

“U.S. firms have designed a good deal of their domestic lobbying on BEPS along the lines that BEPS is all about bashing American success,” said Kleinbard, who was formerly Chief of Staff of the U.S. Congress’s Joint Committee on Taxation.

But he said the case of SAP shows the United States is also a victim of tax avoidance by foreign companies; the U.S. treasury, too, could benefit from tax reform.

Like all companies, SAP has a responsibility to investors to maximise returns by minimising costs, including taxes. “Clearly, if I was an investor looking at two identical companies, I would choose the one with the lower tax rate,” said Robert Jakobsen, senior equity analyst at Jyske Bank in Denmark, who covers SAP.

ACQUIRED TAX EFFICIENCY

In January 2012, a fund manager at a presentation for investors in Frankfurt asked SAP’s chief financial officer, Werner Brandt, how the company had managed to reduce its effective tax rate so much “in the last few years”, given “an environment where countries need more taxes and have stretched budgets.”

The question prompted laughter from the room and from Brandt himself, a video of the event on SAP’s website shows.

“I hope you understand that I do not want to go into too much detail here,” he responded. “But if you think of acquisitions and the way how you finance and structure acquisitions, this could help you, in order to reduce your tax rate.”

SAP spokesman Jim Dever said Brandt’s comment referred to U.S. acquisitions made by SAP in recent years. He declined to name the acquisitions, though he said Brandt’s answer did not refer to SAP’s biggest pre-2012 deal, the $7 billion takeover of French software company Business Objects in 2008.

Even so, SAP’s accounts show the Business Objects deal did contribute to a significant reduction in taxes by allowing it to report large profits in Ireland. In fact, Business Objects’ Irish operation gave SAP a low-tax home for its intellectual property which could then charge other parts of the group for the right to use the software, thereby shifting profits to Dublin.

Profitability at Business Objects’ Irish subsidiary, Business Objects Software Ltd., has risen tenfold since the deal. Last year, the Dublin-registered unit reported profits of 381 million euros, making it the second most profitable arm of the group after the main German operation.

SAP says this high profitability is due to the fact that Dublin owns the intellectual property underpinning Business Objects’ branded software. The firm charges affiliates royalties for licensing this, and the affiliates then sell the software to clients.

Dublin did not develop the original software and did not even have a research department before 2008, said Andrey Grigoriev, Senior Director at Business Objects. It accumulated the know-how by buying rights to software that had been developed by affiliates in the United States, the UK, Canada and France.

Since SAP took over, Business Objects has established a research unit in Dublin. The centre, known as “App Haus”, sits on the third floor of one of SAP’s glass-and-stone clad buildings at Citywest. Its look is deliberately unfinished: part-plastered walls, exposed wooden supports, uncarpeted steel floors, furniture on wheels and floor-to-ceiling whiteboards which hang from rails. Mark Brennan, Vice President Development, Ireland, said the “garage” look aims to foster the energy of a start-up.

In 2011, the last year for which full accounts for Business Objects Software are available, it spent 180 million euros on research. Less than 10 percent of that was spent in Ireland.

Business Objects Software is markedly more profitable than the company’s other units that develop or sell software. At the group’s main North American “development, research, and innovation” centre, SAP LABS, LLC, in Palo Alto, California, where more than 2,000 staff work, profit margins were 4 percent in 2011, accounts show. SAP (UK) Ltd., which sells a range of SAP software in Britain, had margins of just 7 percent, a similar level to other SAP distribution subsidiaries. Dublin’s profit margins were 37 percent in 2011. It made that by charging other group companies more than 700 million euros for its intellectual property, while paying less than 180 million euros to subsidiaries that develop the software.

SAP’s customers and programmers are largely based in the United States, Canada, France, Japan, the UK and Germany. If its profit were allocated more closely in line with sales and research this would boost its tax bill, potentially by more than 60 million euros based on headline tax rates. SAP said it follows international rules on transfer pricing – the common practice of pricing inter-company transactions. It said the high profits in Ireland were the unintentional result of its application of international tax rules.

Kleinbard, the California law professor, said the structure of the Irish unit was lawful but defied economic logic: “It’s just not credible to say that a company which has such a low percentage of sales in a country can generate so much profit there.”

LOAN TO SELF

Two floors beneath the “App Haus” sits the other key to SAP’s tax efficiency.

Visitors might easily miss the small plaque on the wall, and the slightly darker hue in the carpet tiles that designate the shift from the realm of Business Objects Software to that of its subsidiary, SAP Ireland US-Financial Services Ltd. But the three staff who work here are far and away the most productive in the group, SAP accounts show. On average, each one of them generated profits of 107 million euros in 2012.

The company said SAP Ireland US-Financial Services was established in 2010 to help manage foreign currency risk and finance U.S. acquisitions. The unit also helps reduce taxes by creating large interest costs in Germany and the United States and large interest income in Ireland.

How does it do this? Take an example from 2010. SAP AG – the German-registered group parent - raised 2.2 billion euros by issuing Eurobonds, and injected the money as equity into SAP Ireland US-Financial Services. The bonds generated annual interest payments of 57 million euros which were not offset by interest received from Ireland, so SAP’s taxable income was reduced by a similar amount, the accounts show.

The Irish financing unit then borrowed additional funds from U.S. lenders at an interest rate of less than 3 percent, which it lent on to SAP America Inc., to which it charged a higher interest rate. By the end of 2011, the Dublin subsidiary had extended loans of $4.25 billion to its U.S. affiliate, and generated interest income of $300 million that year – equivalent to an interest rate of 8 percent.

If SAP America had borrowed on the public markets at 3 percent, the lower interest charge would also have boosted its profit – and its taxes.

SAP’s Dever said the corporate structure was not motivated by tax. He said the financing arm was established in Ireland because not all countries allow firms to report their accounts in foreign currencies - SAP Ireland US-Financial Services uses dollars.

The interest rates charged to SAP America were reasonable, SAP said, because they reflect the rates that such a company would have to pay in the open market if it did not have a guarantee from a cash-rich parent.

Professor Michael Graetz, at the Columbia University law school, said the arrangement was a well established tax-reduction strategy.

“They’re stripping the income out of the U.S. into Ireland, using debt,” he said. “Income is flocking to a low-tax country and the deductions are flocking to high-tax countries.”

ACTION PLAN

Much of the debate around corporate tax over the past year has focused on U.S. companies. The SAP example shows firms from other countries use the same techniques.

Reimar Pinkernell, tax partner at law firm Flick Gocke Schaumburg in Bonn, said tough international competition in businesses like software meant Europeans had to take advantage of tax optimisation opportunities.

The OECD, which advises its mainly rich nation members on taxation, has recommended countries seek to end many contrived tax avoidance practices. In July it published an Action Plan that highlighted firms' use of inter-company debt and the way they locate intellectual property in low tax areas as problems to address.

The governments of all the Group of 20 leading nations, including Germany, have backed that plan.

Business groups on both sides of the Atlantic have pushed back, saying the drive fosters an anti-business environment that could hamper growth.

“U.S. companies are concerned about the impact of the Action Plan,” said Carol Doran Klein, International Tax Counsel with the United States Council for International Business (USCIB), which counts over 300 of the biggest U.S. multinationals among its members. “There is a sense that U.S. companies are targets.”

source: www.abs-cbnnews.com