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The effect of the tax reform act of 1986 on the location of assets in financial services firms

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  • Altshuler, Rosanne
  • Hubbard, R. Glenn

Abstract

This paper examines the effects of the Tax Reform Act of 1986 on the international location decisions of U.S. financial services firms. The Act included rule changes that made it substantially more difficult for U.S. firms to defer U.S. taxes on overseas financial services income held in low-tax jurisdictions. These same rule changes were not applied to other forms of income; in particular, income generated from active manufacturing operations was still eligible for deferral after the Act. We use information from the tax returns of U.S. corporations to examine how local taxes affect the allocation of assets held abroad. We find that, before the Act, the location of assets in financial subsidiaries was responsive to differences in host country tax rates across jurisdictions. However, after the Act, differences in host country tax rates no longer explain the distribution of assets held in financial services subsidiaries abroad. In contrast, we find that assets held in manufacturing subsidiaries have become more sensitive to variations in tax rates. Our results suggest that the tightening of the anti-deferral provisions applicable to financial services companies has been successful in neutralizing the effect of host country income taxes on investment location decisions.
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  • Altshuler, Rosanne & Hubbard, R. Glenn, 2003. "The effect of the tax reform act of 1986 on the location of assets in financial services firms," Journal of Public Economics, Elsevier, vol. 87(1), pages 109-127, January.
    • Handle: RePEc:eee:pubeco:v:87:y:2003:i:1:p:109-127
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    Cited by:

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    2. Kari Seppo, 2015. "Corporate tax in an international environment – Problems and possible remedies," Nordic Tax Journal, Sciendo, vol. 2015(1), pages 1-16, September.
    3. Axel Prettl & Dominik Hagen, 2023. "Multinational ownership patterns and anti-tax avoidance legislation," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 30(3), pages 565-634, June.
    4. Michael P Devereux, 2007. "The Impact of Taxation on the Location of Capital, Firms and Profit: a Survey of Empirical Evidence," Working Papers 0702, Oxford University Centre for Business Taxation.
    5. Harendt, Christoph, 2018. "Tax Influence on Financial Structures of M&As," VfS Annual Conference 2018 (Freiburg, Breisgau): Digital Economy 181552, Verein für Socialpolitik / German Economic Association.
    6. Eichfelder, Sebastian & Jacob, Martin & Kalbitz, Nadine & Wentland, Kelly, 2023. "How do corporate tax rates alter conforming tax avoidance?," arqus Discussion Papers in Quantitative Tax Research 277, arqus - Arbeitskreis Quantitative Steuerlehre.
    7. Watanabe, Yuichi, 2010. "Tax differentials and inflow of foreign direct investments : evidence from foreign operations of U.S. multinational companies," IDE Discussion Papers 263, Institute of Developing Economies, Japan External Trade Organization(JETRO).
    8. Martin Ruf & Alfons J. Weichenrieder, 2012. "The taxation of passive foreign investment: lessons from German experience," Canadian Journal of Economics, Canadian Economics Association, vol. 45(4), pages 1504-1528, November.
    9. Haufler, Andreas & Mardan, Mohammed & Schindler, Dirk, 2018. "Double tax discrimination to attract FDI and fight profit shifting: The role of CFC rules," Journal of International Economics, Elsevier, vol. 114(C), pages 25-43.
    10. Mardan, Mohammed & Haufler, Andreas & Schindler, Dirk, 2014. "An Economic Rationale for Controlled-Foreign-Corporation Rules," VfS Annual Conference 2014 (Hamburg): Evidence-based Economic Policy 100405, Verein für Socialpolitik / German Economic Association.
    11. Nora Alice Paulus, 2022. "The anti‐tax‐avoidance directive: An initiative to successfully curb profit shifting?," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 24(3), pages 529-546, June.
    12. Egger, Peter H. & Wamser, Georg, 2015. "The impact of controlled foreign company legislation on real investments abroad. A multi-dimensional regression discontinuity design," Journal of Public Economics, Elsevier, vol. 129(C), pages 77-91.
    13. Harendt, Christoph, 2018. "Tax influence on financial structures of M&As," ZEW Discussion Papers 18-004, ZEW - Leibniz Centre for European Economic Research.
    14. von Hagen, Dominik & Harendt, Christoph, 2017. "Impact of controlled foreign corporation rules on post-acquisition investment and profit shifting in targets," ZEW Discussion Papers 17-062, ZEW - Leibniz Centre for European Economic Research.

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    More about this item

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm

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