Evaluating International Tax Reform

(w/ J. R. Hines Jr.) National Tax Journal 56, no. 3 (September 2003), 487-502.

This paper introduces “capital ownership neutrality” (CON) and “national ownership neutrality” (NON) as benchmarks for evaluating the desirability of international tax reforms, and applies them to analyze recent U.S. tax reform proposals.

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A Multinational Perspective on Capital Structure Choice and Internal Capital Markets

(w/ C. F. Foley and J. R. Hines Jr.) Journal of Finance 59, no. 6 (December 2004), 2451-2488 (Lead Article). Reprinted in S. Claessens and L. Laeven (eds.), A Reader in International Corporate Finance, The World Bank, 2006.

This paper examines the impact of local tax rates and capital market conditions on the level and composition of borrowing by foreign affiliates of American multinational corporations. 

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The Divergence Between Book Income and Tax Income

in J. Poterba (ed.) Tax Policy and the Economy 17 (Cambridge, MA: MIT Press, 2003), 169-206. This paper is a revision of NBER Working Paper 8866, entitled "The Corporate Profit Base, Tax Sheltering Activity, and the Changing Nature of Employee Compensation."

This paper examines the evolution of the corporate profit base and the relationship between book income and tax income for U.S. corporations over last two decades. 

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Chains of Ownership, Regional Tax Competition and Foreign Direct Investment

(w/ C.F. Foley and J.R. Hines Jr.) Foreign Direct Investment in the Real and Financial Sector of Industrial Countries, in Heinz Herrmann and Robert Lipsey (ed.), Springer Verlag: Heidelberg (2003), 61-98.

This paper considers the effect of taxation on the location of foreign direct investment (FDI) and taxable income reported by multinational firms with particular attention to the regional dynamics of tax competition and the role of chains of ownership.

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Repatriation Taxes and Dividend Distortions

(w/ C. F. Foley and J. R. Hines Jr.) National Tax Journal 54, no. 4 (December 2001), 829-851.

This paper analyzes the effect of repatriation taxes on dividend payments by the foreign affiliates of American multinational firms. The United States taxes the foreign incomes of American companies, grants credits for any foreign income taxes paid, and defers any taxes due on the unrepatriated earnings for those affiliates that are separately incorporated abroad. This system thereby imposes repatriation taxes that vary inversely with foreign tax rates and that differ across organizational forms. As a consequence, it is possible to measure the effect of repatriation taxes by comparing the behavior of foreign subsidiaries that are subject to different tax rates and by comparing the behavior of foreign incorporated and unincorporated affiliates. Evidence from a large panel of foreign affiliates of U.S. firms from 1982 to 1997 indicates that 1 percent lower repatriation tax rates are associated with 1 percent higher dividends. This implies that repatriation taxes reduce aggregate dividend payouts by 12.8 percent, and, in the process, generate annual efficiency losses equal to 2.5 percent of dividends. These effects would disappear if the United States were to exempt foreign income from taxation.