The Taxation of Foreign Profits: a Unified View
This paper synthesizes and extends the literature on the taxation of foreign source income in a framework that covers both greenfield and acquisition investment, and a general constraint linking investment at home and abroad for the multinational by introducing a cost of adjustment for the mobile factor. Unless the cost of adjustment is zero, the domestic tax on foreign-source income should always be set to ensure the optimal allocation of the mobile factor between domestic and foreign assets and should follow the classical rules in the literature; national optimality requires the deduction rule, and global optimality requires the credit rule. Only in the zero-cost case does exemption become optimal. Allowances can be set so as to ensure that domestic and foreign asset purchases are undistorted by the tax system: this requires a cash-flow tax on domestic investment in the greenfield case, and a cross-border cash flow tax on foreign investment in both cases. These basic results extend to various extensions of the model.
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- Joel Slemrod & Carl Hansen & Roger Procter, 1994.
"The Seesaw Principle in International Tax Policy,"
NBER Working Papers
4867, National Bureau of Economic Research, Inc.
- Hamermesh, Daniel S. & Pfann, Gerard Antonie, 1996.
"Adjustment Costs in Factor Demand,"
CEPR Discussion Papers
1371, C.E.P.R. Discussion Papers.
- Michael P. Devereux, 2004. "Some Optimal Tax Rules for International Portfolio and Direct Investment," FinanzArchiv: Public Finance Analysis, Mohr Siebeck, Tübingen, vol. 60(1), pages 1-, April.
- Michael P. Devereux & R. Glenn Hubbard, 2000.
NBER Working Papers
7920, National Bureau of Economic Research, Inc.
- Becker, Johannes & Fuest, Clemens, 2011.
"Source versus residence based taxation with international mergers and acquisitions,"
Journal of Public Economics,
Elsevier, vol. 95(1-2), pages 28-40, February.
- Becker, Johannes & Fuest, Clemens, 2011. "Source versus residence based taxation with international mergers and acquisitions," Journal of Public Economics, Elsevier, vol. 95(1), pages 28-40.
- Johannes Becker & Clemens Fuest, 2009. "Source versus Residence Based Taxation with International Mergers and Acquisitions," CESifo Working Paper Series 2854, CESifo Group Munich.
- Johannes Becker & Clemens Fuest, 2010.
"Taxing Foreign Profits With International Mergers And Acquisitions,"
International Economic Review,
Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 51(1), pages 171-186, 02.
- Johannes Becker & Clemens Fuest, 2007. "Taxing Foreign Profits with International Mergers and Acquisitions," Working Papers 0719, Oxford University Centre for Business Taxation.
- Desai, Mihir A. & Hines, James R. Jr., 2004. "Old Rules and New Realities: Corporate Tax Policy in a Global Setting," National Tax Journal, National Tax Association, vol. 57(4), pages 937-60, December.
- Grubert, Harry, 2005. "Comment on Desai and Hines, "Old Rules and New Realities: Corporate Tax Policy in a Global Setting"," National Tax Journal, National Tax Association, vol. 58(2), pages 263-74, June.
- Pfann, Gerald A. & Verspagen, Bart, 1989. "The structure of adjustment costs for labour in the Dutch manufacturing sector," Economics Letters, Elsevier, vol. 29(4), pages 365-371.
- Gordon, Roger H. & Varian, Hal R., 1989.
"Taxation of asset income in the presence of a world securities market,"
Journal of International Economics,
Elsevier, vol. 26(3-4), pages 205-226, May.
- Roger H. Gordon & Hal R. Varian, 1986. "Taxation of Asset Income in the Presence of a World Securites Market," NBER Working Papers 1994, National Bureau of Economic Research, Inc.
- Johannes Becker, 2009.
"Taxation of Foreign Profits with Heterogeneous Multinational Firms,"
CESifo Working Paper Series
2899, CESifo Group Munich.
- Johannes Becker, 2013. "Taxation of Foreign Profits with Heterogeneous Multinational Firms," The World Economy, Wiley Blackwell, vol. 36(1), pages 76-92, 01.
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