The Effect of Financial Constraints on Tax-Motivated Income Shifting by U.S. Multinationals

The Effect of Financial Constraints on Tax-Motivated Income Shifting by U.S. Multinationals PDF Author: Scott Dyreng
Publisher:
ISBN:
Category :
Languages : en
Pages : 56

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Book Description
When a U.S. multinational corporation shifts income from the U.S. to foreign jurisdictions, it incurs costs and reaps benefits. The benefits may be reduced if the shifted income must be returned to the U.S. as a dividend in the short term and face the same U.S. tax it would have if the income had not been shifted. Firms, then, have incentive to defer repatriation of earnings and to fund domestic cash needs with external financing. The cost of external financing, however, is increasing in financial constraints, leading to the prediction that constrained firms will be unable to defer repatriation and, therefore, will reap no benefits from shifting. Consistent with this prediction, we find that financially constrained firms shift less income from the U.S. to foreign countries than their unconstrained peers. We estimate that financially constrained firms shift out 20% less of pre-shifted income than unconstrained firms. Translating this percentage to dollar values, the mean (median) constrained firm shifts $16 million ($7 million) out of the U.S. each year while the mean (median) unconstrained firm shifts $321 million ($134 million) out of the U.S. each year. Assuming that the inability to defer repatriation is the primary constraint preventing the U.S. worldwide tax system from being a de facto territorial system, we use our findings to estimate that changing to a pure territorial tax system would increase outbound income shifting by U.S. multinationals by 8%.

The Effect of Financial Constraints on Tax-Motivated Income Shifting by U.S. Multinationals

The Effect of Financial Constraints on Tax-Motivated Income Shifting by U.S. Multinationals PDF Author: Scott Dyreng
Publisher:
ISBN:
Category :
Languages : en
Pages : 56

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Book Description
When a U.S. multinational corporation shifts income from the U.S. to foreign jurisdictions, it incurs costs and reaps benefits. The benefits may be reduced if the shifted income must be returned to the U.S. as a dividend in the short term and face the same U.S. tax it would have if the income had not been shifted. Firms, then, have incentive to defer repatriation of earnings and to fund domestic cash needs with external financing. The cost of external financing, however, is increasing in financial constraints, leading to the prediction that constrained firms will be unable to defer repatriation and, therefore, will reap no benefits from shifting. Consistent with this prediction, we find that financially constrained firms shift less income from the U.S. to foreign countries than their unconstrained peers. We estimate that financially constrained firms shift out 20% less of pre-shifted income than unconstrained firms. Translating this percentage to dollar values, the mean (median) constrained firm shifts $16 million ($7 million) out of the U.S. each year while the mean (median) unconstrained firm shifts $321 million ($134 million) out of the U.S. each year. Assuming that the inability to defer repatriation is the primary constraint preventing the U.S. worldwide tax system from being a de facto territorial system, we use our findings to estimate that changing to a pure territorial tax system would increase outbound income shifting by U.S. multinationals by 8%.

International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots

International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots PDF Author: Sebastian Beer
Publisher: International Monetary Fund
ISBN: 148436399X
Category : Business & Economics
Languages : en
Pages : 45

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Book Description
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.

Taxing Multinational Corporations

Taxing Multinational Corporations PDF Author: Martin Feldstein
Publisher: University of Chicago Press
ISBN: 0226241882
Category : Business & Economics
Languages : en
Pages : 126

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Book Description
In the increasingly global business environment of the 1990s, policymakers and executives of multinational corporations must make informed decisions based on a sound knowledge of U.S. and foreign tax policy. Written for a nontechnical audience, Taxing Multinational Corporations summarizes the up-to-the-minute research on the structure and effects of tax policies collected in The Effects of Taxation on Multinational Corporations. The book covers such practical issues as the impact of tax law on U.S. competitiveness, the volume and location of research and development spending, the extent of foreign direct investment, and the financial practices of multinational companies. In ten succinct chapters, the book documents the channels through which tax policy in the United States and abroad affects plant and equipment investments, spending on research and development, the cost of debt and equity finance, and dividend repatriations by United States subsidiaries. It also discusses the impact of U.S. firms' outbound foreign investment on domestic and foreign economies. Especially useful to nonspecialists is an appendix that summarizes current United States rules for taxing international income.

The Effects of Taxation on Multinational Corporations

The Effects of Taxation on Multinational Corporations PDF Author: Martin Feldstein
Publisher: University of Chicago Press
ISBN: 0226241874
Category : Business & Economics
Languages : en
Pages : 338

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Book Description
The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.

The Multilateral Convention on Mutual Administrative Assistance in Tax Matters Amended by the 2010 Protocol

The Multilateral Convention on Mutual Administrative Assistance in Tax Matters Amended by the 2010 Protocol PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264115609
Category :
Languages : en
Pages : 112

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Book Description
This publication contains the official text of the Multilateral Convention on Mutual Assistance in Tax Matters as amended by the 2010 Protocol.

Tax and Corporate Governance

Tax and Corporate Governance PDF Author: Wolfgang Schön
Publisher: Springer Science & Business Media
ISBN: 3540772766
Category : Business & Economics
Languages : en
Pages : 423

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Book Description
Academic research shows that well-known principal-agent and capital market problems are strongly influenced by tax considerations. Against this background, this volume is the first to present a fully-fledged overview of the interdependence of tax and corporate governance. Not only the basic political, legal and economic questions but also major topics like income measurement, shareholding structures, corporate social responsibility and tax shelter disclosure are covered.

Taxes and Business Strategy

Taxes and Business Strategy PDF Author: Myron S. Scholes
Publisher:
ISBN: 9781292065571
Category :
Languages : en
Pages : 528

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Book Description
For MBA students and graduates embarking on careers in investment banking, corporate finance, strategy consulting, money management, or venture capital Through integration with traditional MBA topics, Taxes and Business Strategy, Fifth Edition provides a framework for understanding how taxes affect decision-making, asset prices, equilibrium returns, and the financial and operational structure of firms. Teaching and Learning Experience This program presents a better teaching and learning experience-for you and your students: *Use a text from an active author team: All 5 authors actively teach the tax and business strategy course and provide students with relevant examples from both classroom and real-world consulting experience. *Teach students the practical uses for business strategy: Students learn important concepts that can be applied to their own lives. *Reinforce learning by using in-depth analysis: Analysis and explanatory material help students understand, think about, and retain information.

International Taxation and Multinational Activity

International Taxation and Multinational Activity PDF Author: James R. Hines
Publisher: University of Chicago Press
ISBN: 0226341755
Category : Business & Economics
Languages : en
Pages : 285

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Book Description
Because the actions of multinational corporations have a clear and direct effect on the flow of capital throughout the world, how and why these firms behave the way they do is a major issue for national governments and their policymakers. With an unprecedented ability to adjust the scale, character, and location of their global operations, international corporations have become increasingly sensitive to the kind and degree of tax obligations imposed on them by both host and home countries. Tax rules affect the volume of foreign direct investment, corporate borrowing, transfer pricing, dividend and royalty payments, and research and development. National governments that tax the profits of international firms face important challenges in designing tax policies to attract them. This collection examines the global ramifications of tax policies, offering up-to-date, theoretically innovative, and empirically sound perspectives on a problem of immense significance to future economic growth around the globe.

Path to Prosperity

Path to Prosperity PDF Author: Jason Furman
Publisher: Rowman & Littlefield
ISBN: 0815701543
Category : Business & Economics
Languages : en
Pages : 417

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Book Description
Since its launch in 2006, the Hamilton Project at Brookings has produced extensive research on how to create a growing economy that benefits all Americans. Its pragmatic work aims to increase opportunities for broad-based wealth, economic security, and enduring growth. Path to Prosperity, the first book to emerge from the Hamilton Project, presents important and original work to that end. P ath to Prosperity focuses on three key criteria for fostering broadly shared economic growth: enhancing economic security, building a highly skilled work force, and reforming the tax system. Income security proposals offer methods for reforming unemployment insurance, protecting against the risk of reemployment at a lower wage after job loss, and improving incentives for retirement saving. Education proposals build human capital by improving each level of education, from preschool programs for poor children to graduate fellowships in math and science. The tax proposals seek to make taxation simpler, more progressive, and better suited to a global economy. Contributors include Roger C.Altman, Reuven S.Avi-Yonah, Jason E. Bordoff, Kimberly A. Clausing, Susan M. Dynarski, Molly E. Fifer, Richard B. Freeman, Jason Furman,William G. Gale,Austan Goolsbee, Robert Gordon, Jonathan Gruber,Thomas J. Kane, Lori Kletzer, Jeffrey R. Kling, Alan B. Krueger, Jens Ludwig, Peter R. Orszag, Howard F. Rosen, Robert Rubin, Isabel Sawhill, Judith E. Scott-Clayton, and Douglas O. Staiger.

Capital Structure and International Debt Shifting

Capital Structure and International Debt Shifting PDF Author: Mr. Luc Laeven
Publisher: International Monetary Fund
ISBN: 1451910568
Category : Business & Economics
Languages : en
Pages : 40

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Book Description
This paper presents a model of a multinational firm''s optimal debt policy that incorporates international taxation factors. The model yields the prediction that a multinational firm''s indebtedness in a country depends on a weighted average of national tax rates and differences between national and foreign tax rates. These differences matter because multinationals have an incentive to shift debt to high-tax countries. The predictions of the model are tested using a novel firm-level dataset for European multinationals and their subsidiaries, combined with newly collected data on the international tax treatment of dividend and interest streams. Our empirical results show that corporate debt policy indeed not only reflects domestic corporate tax rates but also differences in international tax systems. These findings contribute to our understanding of how corporate debt policy is set in an international context.