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Currency Denomination of Intercompany Debt and Multinational Taxes


  • Thomas J. O'Brien


For multinational companies (MNCs) with foreign subsidiaries, the currency denomination of intercompany debt can have important effects on both taxes and financial statements. This paper analyzes the choice between an intercompany loan denominated in the home currency and one denominated in the subsidiary's functional currency. Using U.S. rules for financial accounting and taxes, the author demonstrates the expected impact of the loan's currency denomination on the expected level and variability of an MNCs overall taxes in the case where it has excess foreign tax credits. Copyright Copyright (c) 2009 Morgan Stanley.

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  • Thomas J. O'Brien, 2009. "Currency Denomination of Intercompany Debt and Multinational Taxes," Journal of Applied Corporate Finance, Morgan Stanley, vol. 21(3), pages 86-94.
  • Handle: RePEc:bla:jacrfn:v:21:y:2009:i:3:p:86-94

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    References listed on IDEAS

    1. Mihir A. Desai & C. Fritz Foley & James R. Hines, 2004. "A Multinational Perspective on Capital Structure Choice and Internal Capital Markets," Journal of Finance, American Finance Association, vol. 59(6), pages 2451-2487, December.
    2. 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.
    3. Chowdhry, Bhagwan & Coval, Joshua D., 1998. "Internal financing of multinational subsidiaries: Debt vs. equity1," Journal of Corporate Finance, Elsevier, vol. 4(1), pages 87-106, March.
    4. Stephen L. Curtis, 2008. "Transfer Pricing for Corporate Treasury in the Multinational Enterprise," Journal of Applied Corporate Finance, Morgan Stanley, vol. 20(2), pages 97-112.
    5. Alan C Shapiro, 1984. "The Impact of Taxation on the Currency-of-Denomination Decision for Long-Term Foreign Borrowing and Lending," Journal of International Business Studies, Palgrave Macmillan;Academy of International Business, vol. 15(1), pages 15-25, March.
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