“…In comparison with other countries, Brazil has unique international tax rules, such as formulaic rules for transfer pricing, an income tax treaty network that is outdated and overreaching antideferral rules for Brazil's MNCs. Since Brazil is considered a high‐tax jurisdiction, for U.S. multinational companies, it is isolated as a likely source of double‐taxation without potential for relief from symmetric systems or treaty provisions, not as an opportunity for deferral of low‐taxed earnings or as a regional holding company (Ilarraz, ; Martins & Souza, ; Rocha, ; L. L. Rodrigues, Schmidt, & dos Santos, ; C. F. Silva, ).…”