This paper analyzes the effects of the U.S. tax treatment of the R&D activities of American multinationals. Recent evidence indicates that the level of R&D spending is highly sensitive to its after-tax cost. The U.S. Tax Reform Act of 1986 reduced the tax deductions that many American firms can claim for their R&D expenses incurred in the U.S., and on this basis, observers predicted that American firms would react to the tax change by significantly increasing the fraction of their R&D that they perform abroad. Aggregate data indicate that this fraction instead stayed roughly constant, at around 10%. An important reason why U.S. firms did not move more of their total R&D activity offshore is that U.S. tax law provides quite generous treatment of R&D performed in the U.S. for use abroad by firms with excess foreign tax credits, and the Tax Reform Act of 1986 significantly increased the number of American firms with excess foreign tax credits. Hence, the 1986 tax change increased the cost of U.S.-based R&D for some American firms, and reduced it for others, with little impact on the overall fraction of R&D spending that U.S. firms do abroad. One consequence of the tax law changes of the late 1980s is that, by 1991, the tax treatment of foreign-source royalties received by American firms with excess foreign tax credits has five times the revenue impact of the Research and Experimentation Tax Credit.
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Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number
4574.
Length: Date of creation: May 1994 Date of revision: Handle: RePEc:nbr:nberwo:4574
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Find related papers by JEL classification: H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
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.:
Zvi Griliches & Jacques Mairesse, 1984.
"Productivity and R&D at the Firm Level,"
NBER Chapters,
in: R & D, Patents, and Productivity, pages 339-374
National Bureau of Economic Research, Inc.
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