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Credit and Deferral as International Investment Incentives

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Author Info
James R. Hines Jr.
Abstract

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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Publisher Info
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 1994
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Publication status: published as Journal of Public Economics, Vol. 55, no. 2, pp. 323-347, October 1994
Handle: RePEc:nbr:nberwo:4191

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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.:

  1. 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:
  2. 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)
  3. 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:
  4. repec:fth:coluec:478 is not listed on IDEAS
  5. 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:
  6. 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.
  7. Hines, J.R. & Rice, E.M., 1990. "Fiscal Paradise: Foreign Tax Havens And American Business," Papers 56, Princeton, Woodrow Wilson School - Discussion Paper.
  8. Altshuler, R. & Fulghieri, P., 1990. "Incentive Effects Of Foreign Tax Credits On Multinationals," Discussion Papers 1990_11, Columbia University, Department of Economics.
  9. 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)
  10. Hines, J.R., 1990. "The Flight Paths Of Migratory Corporations," Papers 65, Princeton, Woodrow Wilson School - Discussion Paper.
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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.)

  1. Rosanne Altshuler, 2000. "Recent Developments in the Debate on Deferral," Departmental Working Papers 200013, Rutgers University, Department of Economics. [Downloadable!]
  2. 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)
  3. 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:
  4. 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)
  5. 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)
  6. 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)
  7. 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!]
  8. 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!]
  9. 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:
  10. 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:
  11. 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!]
  12. Lindhe, Tobias, 2001. "Mitigating Double Taxation in an Open Economy," Working Paper Series 2001:5, Uppsala University, Department of Economics. [Downloadable!]
  13. 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)
  14. Kari, Seppo & Ylae-Liedenpohja, Jouko, 2003. "Taxation and Valuation of International Real Investments," CESifo Working Paper Series CESifo Working Paper No. , CESifo GmbH. [Downloadable!]
  15. 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)
  16. 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:
  17. 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)
  18. 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:
  19. James R. Hines Jr., 2004. "Do Tax Havens Flourish?," NBER Working Papers 10936, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  20. 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)
  21. 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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