Review of J. R. Hines, Jr. (ed.), International Taxation and Multinational Activity, (Chicago: University of Chicago Press, 2001)

 National Tax Journal 55, no. 4 (December 2002), 845-848.

Within the last three decades, federal and subnational governments around the world have become increasingly appreciative of the benefits of foreign direct investment and increasingly aggressive in their efforts to attract multinational firms. 

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Corporate Inversions: Stanley Works and the Lure of Tax Havens

(w/ J. R. Hines Jr. and M. Veblen) HBS Case 203-008. 

In response to Stanley Work's announcement that it is moving to Bermuda--and the associated jump in market value--a major competitor sets out to determine how the market is valuing the consequences of moving to a tax haven and whether his company should invert to a tax haven. 

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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.