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The Effect of the Tax Reform Act of 1986 on the Location of Assets

Author

Listed:
  • Rosanne Altshuler

    (Rutgers University, Department of Economics)

  • R. Glenn Hubbard

    (Columbia University)

Abstract

This paper examines the effects of the Tax Reform Act of 1986 on the international location decisions of U.S. financial services firms. The Act included rule changes that made it substantially more difficult for U.S. firms to defer U.S. taxes on overseas financial services income held in low-tax jurisdictions. These same rule changes were not applied to other forms of income; in particular, income generated from active manufacturing operations was still eligible for deferral after the Act. We use information from the tax returns of U.S. corporations to examine how local taxes affect the allocation of assets held abroad. We find that, before the Act, the location of assets in financial subsidiaries was responsive to differences in host country tax rates across jurisdictions. However, after the Act, differences in host country tax rates no longer explain the distribution of assets held in financial services subsidiaries abroad. In contrast, we find that assets held in manufacturing subsidiaries have become more sensitive to variations in tax rates. Our results suggest that the tightening of the anti-deferral provisions applicable to financial services companies has been successful in neutralizing the effect of host country income taxes on investment location decisions.

Suggested Citation

  • Rosanne Altshuler & R. Glenn Hubbard, 2002. "The Effect of the Tax Reform Act of 1986 on the Location of Assets," Departmental Working Papers 200012, Rutgers University, Department of Economics.
    • Handle: RePEc:rut:rutres:200012
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    References listed on IDEAS

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    1. Feldstein, Martin & Hines, James R. & Hubbard, R. Glenn (ed.), 1995. "Taxing Multinational Corporations," National Bureau of Economic Research Books, University of Chicago Press, edition 1, number 9780226240947, December.
    2. James R. Hines, Jr. & R. Glenn Hubbard & R. Glenn Hubbard, 1995. "Appendix to "Taxing Multinational Corporations"," NBER Chapters, in: Taxing Multinational Corporations, pages 103-106, National Bureau of Economic Research, Inc.
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    4. Hines, James R. Jr., 1999. "The Case against Deferral: A Deferential Reconsideration," National Tax Journal, National Tax Association, vol. 52(n. 3), pages 385-404, September.
    5. Hines, James R. Jr., 1999. "The Case Against Deferral: A Deferential Reconsideration," National Tax Journal, National Tax Association;National Tax Journal, vol. 52(3), pages 385-404, September.
    6. Devereux, Michael P & Hubbard, R Glenn, 2003. "Taxing Multinationals," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 10(4), pages 469-487, August.
    7. Martin Feldstein & James R. Hines Jr. & R. Glenn Hubbard, 1995. "Taxing Multinational Corporations," NBER Books, National Bureau of Economic Research, Inc, number feld95-1, March.
    8. Desai, Mihir A. & Hines Jr., James R., 1999. ""Basket cases": Tax incentives and international joint venture participation by American multinational firms," Journal of Public Economics, Elsevier, vol. 71(3), pages 379-402, March.
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    11. Rosanne Altshuler & T. Scott Newlon & Joel Slemrod, 1993. "The Effects of U.S. Tax Policy on the Income Repatriation Patterns of U. S . Multinational Corporations," NBER Chapters, in: Studies in International Taxation, pages 77-116, National Bureau of Economic Research, Inc.
    12. Giovannini, Alberto & Hubbard, R. Glenn & Slemrod, Joel (ed.), 1993. "Studies in International Taxation," National Bureau of Economic Research Books, University of Chicago Press, edition 1, number 9780226297019, December.
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    Cited by:

    1. Ulrich Schreiber, 2015. "Investitionseffekte des BEPS Aktionsplans der OECD," Schmalenbach Journal of Business Research, Springer, vol. 67(1), pages 102-127, February.
    2. Clifford, Sarah, 2019. "Taxing multinationals beyond borders: Financial and locational responses to CFC rules," Journal of Public Economics, Elsevier, vol. 173(C), pages 44-71.
    3. Sabine Schenkelberg, 2020. "The Cadbury Schweppes judgment and its implications on profit shifting activities within Europe," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 27(1), pages 1-31, February.
    4. Sarah Clifford, 2017. "Taxing multinationals beyond borders: financial and locational responses to CFC rules," EPRU Working Paper Series 17-02, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
    5. Egger, Peter & Wamser, Georg, 2011. "The Impact of Controlled Foreign Company Legislation on Real Investments Abroad: A Two-dimensional Regression Discontinuity Des," CEPR Discussion Papers 8460, C.E.P.R. Discussion Papers.

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    More about this item

    Keywords

    multinational; financial services; international taxation; investment policy; Tax Reform Act of 1986;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods

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