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Income Shifting in U.S. Multinational Corporations

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Author Info
David Harris
Randall Morck
Joel Slemrod
Bernard Yeung

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Abstract

It is often claimed that multinational firms avoid taxes by shifting income from high-tax to low-tax countries. Using a five year panel of data for two hundred large U.S. manufacturing firms, we find that U.S. tax liability, as a fraction either of U.S. sales or U.S. assets, is related to the location of foreign subsidiaries in a way that is consistent with tax-motivated income shifting. Having a subsidiary in a tax haven, Ireland, or one of the "four dragon" Asian countries - all characterized by low tax rates - is associated with lower U.S. tax ratios. Having a subsidiary in a high-tax region is associated with higher U.S. tax ratios. These results suggest that U.S. manufacturing companies shift income out of high-tax countries into the U.S., and from the U.S. to low-tax countries. Such behavior certainly lowers worldwide tax liabilities for larger U.S. manufacturing companies and appears to significantly lower their U.S. tax liabilities as well.

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Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number 3924.

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Date of creation: Dec 1991
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Publication status: published as Studies in Internatioanl Taxationedited by Alberto Giovannini, R. Glenn Hubbard, and Joel Slemrod University of Chicago Press: May 1993
Handle: RePEc:nbr:nberwo:3924

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  1. Hines, J.R. & Rice, E.M., 1990. "Fiscal Paradise: Foreign Tax Havens And American Business," Papers 56, Princeton, Woodrow Wilson School - Discussion Paper.
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  1. Kimberly A. Clausing, 1998. "The Impact of Transfer Pricing on Intrafirm Trade," NBER Working Papers 6688, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  2. Hans Jarle Kind & Helene Midelfart & Guttorm Schjelderup, 2004. "Corporate Tax Systems, Multinational Enterprises, and Economic Integration," CESifo Working Paper Series CESifo Working Paper No. , CESifo GmbH. [Downloadable!]
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  3. Mihir A. Desai & C. Fritz Foley & James R. Hines Jr., 2002. "International Joint Ventures and the Boundaries of the Firm," NBER Working Papers 9115, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  4. Søren Bo Nielsen & Pascalis Raimondos-Møller & Guttorm Schjelderup, . "Tax Spillovers under Separate Accounting and Formula Apportionment," EPRU Working Paper Series 01-07, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics. [Downloadable!]
  5. Joel Slemrod, 1994. "Free-Trade Taxation and Protectionist Taxation," NBER Working Papers 4902, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  6. P. B. Oyelere, C. R. Emmanuel, 1998. "International transfer pricing and income shifting: evidence from the UK," European Accounting Review, Taylor and Francis Journals, vol. 7(4), pages 623-635, December. [Downloadable!] (restricted)
  7. John Christian Langli & Shahrokh Saudagaran, 2004. "Taxable income differences between foreign and domestic controlled corporations in Norway," European Accounting Review, Taylor and Francis Journals, vol. 13(4), pages 713-741, December. [Downloadable!] (restricted)
  8. Kind, Hans Jarle & Schjelderup, Guttorm & Ulltveit-Moe, Karen-Helene, 2001. "Corporate Taxation, Multinational Enterprise and Economic Integration," CEPR Discussion Papers 2753, C.E.P.R. Discussion Papers. [Downloadable!] (restricted)
  9. James R. Hines, Jr., 1995. "Taxes, Technology Transfer, and the R&D Activities of Multinational Firms," NBER Working Papers 4932, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
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