Double taxing these profits gives companies the incentive to either relocate their headquarters out of the country, or shrink international operations and eliminate jobs.

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Clearly, double taxing dividends has negative implications.

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That's because REITs must pay 90% of earnings in dividends, a task made easier since the conversion lets them end the double-taxing of their incomes.

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Taxing transfers (like dividends) amounts to double taxation.

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Taxing the profits both at the level of the company and then also upon distribution is double taxation: something that well designed tax systems try to avoid.

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