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"Basket" Cases: International Joint Ventures After the Tax Reform Act of 1986

  • Mihir A. Desai
  • James R. Hines, Jr.

This paper examines the impact of the Tax Reform Act of 1986 (TRA) on international joint ventures by American firms. The evidence suggests that the TRA had a significant effect on the organizational form of U.S. business activity abroad. The TRA mandates the use of separate credits on income received from foreign corporations owned 50% or less by Americans. This limitation on worldwide averaging greatly reduces the attractiveness of joint ventures to American investors, particularly ventures in low-tax foreign countries. Aggregate data indicate that U.S. participation in international joint ventures fell sharply after 1986. The decline in U.S. joint venture activity is most pronounced in low-tax countries, which is consistent with the incentives created by the TRA. Moreover, joint ventures in low-tax countries use more debt and pay greater royalties to their U.S. parents after 1986, which reflects their incentives to economize on dividend payments

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Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number 5755.

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Date of creation: Sep 1996
Date of revision:
Publication status: published as Journal of Public Economics, Vol. 71, no. 3 (March 1999): 379-402.
Handle: RePEc:nbr:nberwo:5755
Note: PE
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