Working Paper No. 3477 The offshore tax haven affiliates of American corporations account for more than a quarter of US foreign investment, an nearly a third of the foreign profits of US firms. This ...paper analyzes the origins of this tax haven activity and its implications for the US and foreign governments. Based on the behavior of US fins in 1982, it appears that American companies report extraordinarily high profit rates on both their real and their financial investments in tax havens. We calculate from this behavior that the tax rate that maximizes tax revenue for a typical haven is around 6%. The revenue implications for the US are more complicated, since tax havens may ultimately enhance the ability of the US government to tax the foreign earnings of American companies.
Taxing corporate income in the 21st century Auerbach, Alan J; Hines, Jr., James R.; Slemrod, Joel ...
Journal of economic literature,
09/2009, Letnik:
XLVII, Številka:
3
Book Review
Working Paper No. 2931 This paper analyzes the financial flows from foreign subsidiaries of American multinational corporations to their parent corporations in the U.S. These repatriations are ...important not only to U.S. investors, who thereby have access to those funds, but also to the U.S. government, which generally does not tax foreign earnings of controlled foreign corporations until they are repatriated. The paper reviews the current tax system as applied to multinational firms, and considers the incentives it creates for various intra-firm financial transactions (in particular, the form of repatriations). These incentives appear to be inconsistent with historical repatriation patterns from aggregate time-series data on the overseas operations of U.S. multinationals. To resolve this inconsistency, we explore the determinants of distributions by foreign subsidiaries to their U.S. parent corporations, using new micro data on 12,041 controlled foreign corporations (and their 453 U.S. parents) collected from tax returns for 1984. This source exposes variations in distribution patterns not detectable in aggregate data. In particular, the data suggest that most subsidiaries paid no dividends to their parents in 1984, and that the U.S. government collected very little revenue on their foreign income while distorting their internal financial transactions.
Rethinking estate and gift taxation Gale, William G; Hines, Jr., James R.; Slemrod, Joel ...
Journal of economic literature,
06/2003, Letnik:
XLI, Številka:
2
Book Review
U.S. taxation of international income Hufbauer, Gary Clyde; Rooij, Joanna M. van; Hines, Jr., James R.
National tax journal,
03/1993, Letnik:
XLVI, Številka:
1
Book Review