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The Effect of Taxes on Royalties and the Migration of Intangible Assets Abroad

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  • John H. Mutti
  • Harry Grubert
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    Abstract

    Migration of intangible assets from the United States to foreign countries has become easier due to the ability of U.S. firms to create hybrid entities in their affiliates abroad and to reach favorable cost sharing agreements with them. This strategy was particularly encouraged by the U.S. adoption of "check-the-box" regulations in 1997. Rather than receive royalties from affiliates abroad, US parent firms have an incentive to retain abroad in low-tax countries a greater share of the return to their US R&D. Evidence from several sources for years that span the 1997 policy change indicate a significant response by US corporations in utilizing this strategy. BEA data indicate affiliate earnings and profits grew more rapidly than royalty payments to US parents. Payments to U.S. parents for technical services rose even faster, as would be called for under cost sharing agreements. Regression analysis of affiliate data shows that parent R&D was a more important determinant of royalty payments to U.S. parents than it was for affiliate earnings and profits in 1996, but by 2002 it played a larger role in earnings and profits than in royalties. Cost sharing payments from affiliates in Ireland and from pure tax havens (Bermuda, the Cayman Islands, and Luxembourg) are particularly significant, both economically and statistically.

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    File URL: http://www.nber.org/papers/w13248.pdf
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    Bibliographic Info

    Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number 13248.

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    Date of creation: Jul 2007
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    Publication status: published as The Effect of Taxes on Royalties and the Migration of Intangible Assets Abroad , John Mutti, Harry Grubert. in International Trade in Services and Intangibles in the Era of Globalization , Reinsdorf and Slaughter. 2009
    Handle: RePEc:nbr:nberwo:13248

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    1. Nicholas Bloom & Rachel Griffith & John Van Reenen, 2007. "Do R&D Tax Credits Work? Evidence from a Panel of Countries 1979-1997," Discussion Papers 07-020, Stanford Institute for Economic Policy Research.
    2. Rosanne Altshuler & T. Scott Newlon & Harry Grubert, 2002. "Has U.S. Investment Abroad Become More Sensitive to Tax Rates?," Departmental Working Papers 199806, Rutgers University, Department of Economics.
    3. John Mutti & Harry Grubert, 1998. "The Significance of International Tax Rules for Sourcing Income: The Relationship between Income Taxes and Trade Taxes," NBER Chapters, in: Geography and Ownership as Bases for Economic Accounting, pages 259-284 National Bureau of Economic Research, Inc.
    4. Robert E. Baldwin & Robert E. Lipsey & J. David Richards, 1998. "Geography and Ownership as Bases for Economic Accounting," NBER Books, National Bureau of Economic Research, Inc, number bald98-1.
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    Cited by:
    1. Griffith, Rachel & Miller, Helen & O'Connell, Martin, 2011. "Corporate taxes and the location of intellectual property," CEPR Discussion Papers 8424, C.E.P.R. Discussion Papers.
    2. Markle, Kevin S. & Shackelford, Douglas A., 2012. "Cross-Country Comparisons Of Corporate Income Taxes," National Tax Journal, National Tax Association, vol. 65(3), pages 493-527, September.
    3. Atif Mian & Amir Sufi, 2011. "Consumers and the economy, part II: Household debt and the weak U.S. recovery," FRBSF Economic Letter, Federal Reserve Bank of San Francisco, issue jan18.
    4. Dischinger, Matthias & Riedel, Nadine, 2011. "Corporate taxes and the location of intangible assets within multinational firms," Journal of Public Economics, Elsevier, vol. 95(7-8), pages 691-707, August.

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