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Credit and Deferral as International Investment Incentives Author info | Abstract | Publisher info | Download info | Related research | Statistics James R. Hines Jr.
The US government taxes the foreign income of American firms, using a system that grants credits for foreign taxes paid and permits tax deferral for unrepatriated income. This paper shows that the tax system encourages firms to restrict their equity stakes in new foreign investments, and to finance their new investments with considerable debt. These incentives are strongest for US investments in low-tax foreign countries, and exist even when transfer price regulation effectively limits the profit rates foreign subsidiaries can earn. The behavior of US multinationals in 1984 appears to reflect these tax incentives.
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Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number
4191.
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Date of creation: Dec 1994Date of revision:
Publication status: published as Journal of Public Economics, Vol. 55, no. 2, pp. 323-347, October 1994Handle: RePEc:nbr:nberwo:4191Note: ITI PEContact details of provider: Postal: National Bureau of Economic Research, 1050 Massachusetts Avenue Cambridge, MA 02138, U.S.A. Phone: 617-868-3900 Email: Web page: http://www.nber.org More information through EDIRC
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Keywords: Find related papers by JEL classification: H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
References listed on IDEAS Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile , click on "citations" and make appropriate adjustments.:
Hans-Werner Sinn, 1990.
"Taxation and the Birth of Foreign Subsidiaries ,"
NBER Working Papers
3519, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions: Michael J. Boskin & William G. Gale, 1988.
"New Results on the Effects of Tax Policy on the International Location of Investment ,"
NBER Working Papers
1862, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Rosanne Altshuler & T. Scott Newlon, 1991.
"The Effects of U.S. Tax Policy on the Income Repatriation Patterns of U.S. Multinational Corporations ,"
NBER Working Papers
3925, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions: repec:fth:coluec:478 is not listed on IDEAS
Alan J. Auerbach & James R. Hines Jr., 1988.
"Investment Tax Incentives and Frequent Tax Reforms ,"
NBER Working Papers
2492, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions:
Auerbach, A.J. & Hines, Jr.J.R., 1988.
"Investment Tax Incentives And Frequent Tax Reforms ,"
Papers
135, Princeton, Woodrow Wilson School - Public and International Affairs.
Auerbach, Alan J & Hines, James R, Jr, 1988.
"Investment Tax Incentives and Frequent Tax Reforms ,"
American Economic Review ,
American Economic Association, vol. 78(2), pages 211-16, May.
[Downloadable!] (restricted) Berry, Charles H. & Bradford, David F. & Hines, James R. Jr., 1991.
"Arm's Length Pricing: Some Economic Perspectives ,"
CESifo Working Paper Series
CESifo Working Paper No. , CESifo GmbH.
Hines, J.R. & Rice, E.M., 1990.
"Fiscal Paradise: Foreign Tax Havens And American Business ,"
Papers
56, Princeton, Woodrow Wilson School - Discussion Paper.
Altshuler, R. & Fulghieri, P., 1990.
"Incentive Effects Of Foreign Tax Credits On Multinationals ,"
Discussion Papers
1990_11, Columbia University, Department of Economics.
Joel Slemrod, 1991.
"Tax Effects on Foreign Direct Investment in the United States: Evidencefrom a Cross-Country Comparison ,"
NBER Working Papers
3042, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Hines, J.R., 1990.
"The Flight Paths Of Migratory Corporations ,"
Papers
65, Princeton, Woodrow Wilson School - Discussion Paper.
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references Cited by : (explanations , Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile , click on "citations" and make appropriate adjustments.)
Rosanne Altshuler, 2000.
"Recent Developments in the Debate on Deferral ,"
Departmental Working Papers
200013, Rutgers University, Department of Economics.
[Downloadable!]
James R. Hines, Jr., 1996.
"Tax Policy and the Activities of Multinational Corporations ,"
NBER Working Papers
5589, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Rosanne Altshuler & Jason G. Cummins, .
"Tax Policy and the Dynamic Demand for Domestic and Foreign Capital by Multinational Corporations ,"
Computing in Economics and Finance 1997
174, Society for Computational Economics.
[Downloadable!]
Other versions:
Rosanne Altshuler & Jason Cummins, 1998.
"Tax Policy and the Dynamic Demand for Domestic and Foreign Capital by Multinational Corporations ,"
Departmental Working Papers
199808, Rutgers University, Department of Economics.
[Downloadable!] Altshuler, Rosanne & Cummins, Jason, 1997.
"Tax Policy and the Dynamic Demand for Domestic and Foreign Capital by Multinational Corporations ,"
Working Papers
97-31, C.V. Starr Center for Applied Economics, New York University.
[Downloadable!] Mihir A. Desai & James R. Hines Jr., 2001.
"Foreign Direct Investment in a World of Multiple Taxes ,"
NBER Working Papers
8440, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
James R. Hines, Jr., 1997.
"Taxed Avoidance: American Participation in Unsanctioned International Boycotts ,"
NBER Working Papers
6116, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Mihir A. Desai & James R. Hines Jr., 2000.
"The Uneasy Marriage of Export Incentives and the Income Tax ,"
NBER Working Papers
8009, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Rosanne Altshuler & Harry Grubert, 1998.
"Multinational Financial Policy and the Cost of Capital: The Many Roads Home ,"
Departmental Working Papers
199807, Rutgers University, Department of Economics.
[Downloadable!]
Ronald B. Davies, 1999.
"The OECD Model Tax Treaty: Tax Competition and Two-Way Capital ,"
University of Oregon Economics Department Working Papers
2002-7, University of Oregon Economics Department, revised 01 Jan 2002.
[Downloadable!]
Davies, Ronald & Norback, Pehr-Johan & Tekin-Koru, Ayca, 2007.
"The Effect of Tax Treaties on Multinational Firms: New Evidence from Microdata ,"
MPRA Paper
6031, University Library of Munich, Germany.
[Downloadable!]
Other versions: Ronald B. Davies & Thomas A. Gresik, 2001.
"Tax Competition and Foreign Capital ,"
University of Oregon Economics Department Working Papers
2001-15, University of Oregon Economics Department, revised 01 Jan 2001.
[Downloadable!]
Other versions:
Davies, Ronald B & Gresik, Thomas A, 2003.
"Tax Competition and Foreign Capital ,"
International Tax and Public Finance ,
Springer, vol. 10(2), pages 127-45, March.
[Downloadable!] (restricted) Ronald Davies & Thomas Gresik, 2003.
"Tax Competition and Foreign Capital ,"
Asia-Pacific Financial Markets ,
Springer, vol. 10(2), pages 127-145, March.
[Downloadable!] (restricted) Alfons J. Weichenrieder & Jack Mintz, 2008.
"What determines the use of holding companies and ownership chains? ,"
Working Papers
0803, Oxford University Centre for Business Taxation.
[Downloadable!]
Lindhe, Tobias, 2001.
"Mitigating Double Taxation in an Open Economy ,"
Working Paper Series
2001:5, Uppsala University, Department of Economics.
[Downloadable!]
Mihir A. Desai & James R. Hines Jr., 2002.
"Expectations and Expatriations: Tracing the Causes and Consequences of Corporate Inversions ,"
NBER Working Papers
9057, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Kari, Seppo & Ylae-Liedenpohja, Jouko, 2003.
"Taxation and Valuation of International Real Investments ,"
CESifo Working Paper Series
CESifo Working Paper No. , CESifo GmbH.
[Downloadable!]
Roger H. Gordon & James R. Hines Jr., 2002.
"International Taxation ,"
NBER Working Papers
8854, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions:
Gordon, Roger H. & Hines, James Jr, 2002.
"International taxation ,"
Handbook of Public Economics ,
in: A. J. Auerbach & M. Feldstein (ed.), Handbook of Public Economics, edition 1, volume 4, chapter 28, pages 1935-1995
Elsevier.
[Downloadable!] (restricted) Huizinga, Harry & Laeven, Luc & Nicodeme, Gaetan, 2006.
"Capital Structure and International Debt Shifting ,"
CEPR Discussion Papers
5882, C.E.P.R. Discussion Papers.
[Downloadable!] (restricted)
Other versions:
Harry Huizinga & Luc Laeven & Gaëtan Nicodème, 2007.
"Capital Structure and International Debt Shifting ,"
Working Papers CEB
07-015.RS, Université Libre de Bruxelles, Solvay Business School, Centre Emile Bernheim (CEB).
[Downloadable!] Luc Laeven & Gaetan Nicodeme & Harry Huizinga, 2007.
"Capital Structure and International Debt Shifting ,"
IMF Working Papers
07/39, International Monetary Fund.
[Downloadable!] Huizinga, Harry & Laeven, Luc & Nicodeme, Gaetan, 2008.
"Capital structure and international debt shifting ,"
Journal of Financial Economics ,
Elsevier, vol. 88(1), pages 80-118, April.
[Downloadable!] (restricted) Rosanne Altshuler & Harry Grubert, 1996.
"Balance Sheets, Multinational Financial Policy, and the Cost of Capital at Home and Abroad ,"
NBER Working Papers
5810, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Rosanne Altshuler & Harry Grubert, 2002.
"Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy ,"
Departmental Working Papers
200009, Rutgers University, Department of Economics.
[Downloadable!]
Other versions:
Rosanne Altshuler & Harry Grubert, 2001.
"Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy ,"
NBER Working Papers
8144, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted) Altshuler, Rosanne & Grubert, Harry, 2003.
"Repatriation taxes, repatriation strategies and multinational financial policy ,"
Journal of Public Economics ,
Elsevier, vol. 87(1), pages 73-107, January.
[Downloadable!] (restricted) James R. Hines Jr., 2004.
"Do Tax Havens Flourish? ,"
NBER Working Papers
10936, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Mihir A. Desai & C. Fritz Foley & James R. Hines Jr., 2001.
"Repatriation Taxes and Dividend Distortions ,"
NBER Working Papers
8507, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Arkin Vadim & Shevtsova Elmira & Slastnikov Alexander, 1999.
"Tax Incentives for Investment Projects in the Russian Economy ,"
EERC Working Paper Series
99-03e, EERC Research Network, Russia and CIS.
[Downloadable!]
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