IDEAS home Printed from
MyIDEAS: Log in (now much improved!) to save this paper

Issues in the Taxation of Foreign Source Income

Listed author(s):
  • Daniel J. Frisch
Registered author(s):

    This paper examines some aspects of the tax treatment of U.S. multinational corporations. The emphasis is on problems of coordination of the different tax systems faced by the firms. The U.S. corporate income tax must take account of the fact that the firms' over- seas income is taxed by the host governments, in a variety of ways. Currently, the foreign tax credit is the principle mechanism for making these adjustments; it is examined, along with alternative methods such as territorial treatment and a deduction for foreign taxes. The paper also considers the closely related question of coordinating measures of taxable income. The most common method, the arm's length rule, is examined. Alternatives to it, including allocation by shares and a partial case involving allocation of research and development expenses, are also considered. First, the revenue effects of these tax regimes are simulated, with no behavioral responses considered. Responses in location of investment decisions are then included. The data are taken from the corporations' U.S. tax returns, cross-tabulated into approximately 240 industry and country cells.

    If you experience problems downloading a file, check if you have the proper application to view it first. In case of further problems read the IDEAS help page. Note that these files are not on the IDEAS site. Please be patient as the files may be large.

    File URL:
    Download Restriction: no

    Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number 0798.

    in new window

    Date of creation: Nov 1981
    Publication status: published as Frisch, Daniel J. "Issues in the Taxation of Foreign Source Income." Chapter 9 in Behavioral Simulation Methods in Tax Policy Analysis, ed. Martin Feldstein. Chicago: UCP, (1983).
    Handle: RePEc:nbr:nberwo:0798
    Note: PE
    Contact details of provider: Postal:
    National Bureau of Economic Research, 1050 Massachusetts Avenue Cambridge, MA 02138, U.S.A.

    Phone: 617-868-3900
    Web page:

    More information through EDIRC

    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.:

    in new window

    1. Claude Viau & Daniel Hassan & Philippe Evrard, 1977. "Introduction," Cahiers d'Économie Politique, Programme National Persée, vol. 4(1), pages 42-43.
    2. Thomas Horst, 1980. "A Note on the Optimal Taxation of International Investment Income," The Quarterly Journal of Economics, Oxford University Press, vol. 94(4), pages 793-798.
    3. Philippe Evrard & Claude Viau & Daniel Hassan, 1977. "Introduction," Cahiers d'Économie Politique, Programme National Persée, vol. 4(1), pages 10-12.
    4. repec:cai:popine:popu_p1977_32n1_0130 is not listed on IDEAS
    5. Martin Feldstein & David Hartman, 1979. "The Optimal Taxation of Foreign Source Investment Income," The Quarterly Journal of Economics, Oxford University Press, vol. 93(4), pages 613-629.
    6. repec:cai:popine:popu_p1977_32n1_0034 is not listed on IDEAS
    7. repec:cai:popine:popu_p1977_32n1_0298 is not listed on IDEAS
    8. Stiglitz, Joseph E., 1973. "Taxation, corporate financial policy, and the cost of capital," Journal of Public Economics, Elsevier, vol. 2(1), pages 1-34, February.
    Full references (including those not matched with items on IDEAS)

    This item is not listed on Wikipedia, on a reading list or among the top items on IDEAS.

    When requesting a correction, please mention this item's handle: RePEc:nbr:nberwo:0798. See general information about how to correct material in RePEc.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: ()

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If references are entirely missing, you can add them using this form.

    If the full references list an item that is present in RePEc, but the system did not link to it, you can help with this form.

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your profile, as there may be some citations waiting for confirmation.

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    This information is provided to you by IDEAS at the Research Division of the Federal Reserve Bank of St. Louis using RePEc data.