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In addition, Merck, another pharmaceutical company, agreed fork out the IRS $2.3 billion o settle allegations of bokep. It purportedly shifted profits just offshore. In that case, Merck transferred ownership of just two drugs (Zocor and Mevacor) along with shell it formed in Bermuda.

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In 2003 the JGTRRA, or Jobs and Growth Tax Relief Reconciliation Act, was passed, expanding the 10% tax bracket and accelerating some with the changes passed in the 2001 EGTRRA.