The intent of the U.S. Internal Revenue Code is to tax only twice (in the United States) at the corporate level the earnings of a subsidiary.

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The U.S. Internal Revenue Code does not specifically intend to tax the earnings of a subsidiary only twice at the corporate level. Instead, it aims to tax earnings when they are earned by the subsidiary and then again when those earnings are distributed as dividends to the parent company or shareholders, potentially leading to more complex tax situations depending on various factors such as foreign tax credits, tax treaties, and the structure of the corporation.

The Intent of the U