Tax Administration: Comparison of the Report Tax Liabilities of Foreign- and U. S. -Controlled Corporations, 1998-2005
DIANE Publishing, 2009 - 32 pages
Concerns about transfer pricing abuse have led researchers to compare the tax liabilities of foreign- and U.S.-controlled corp. (Transfer prices are the prices related co. charge on inter-co. transactions.) However, such comparisons are complicated because other factors may explain the differences in reported tax liabilities. Three prior reports found differences in the percentages of foreign-controlled and U.S.-controlled corp. reporting no tax liability. This report updates the previous reports by comparing: (1) the tax liabilities of foreign-controlled domestic corp. (FCDC) and U.S.-controlled corp. (USCC) -- including those reporting zero tax liabilities for 1998 through 2005: and (2) characteristics of FCDCs and USCCs such as age, size, and industry. Charts.
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Additional Tables aDifferences between FCDCs analysis of IRS Appendix Average Gross Receipts carrybacks column have sampling corporate tax returns corporations reporting errors of less established no tax FCDCs and USCCs FCDCs have sampling FCDCs Reported Lower foreign GAO analysis gross profit Income Tax Return IRS data large corporations liabilities of FCDCs Liabilities Than USCCs liability in 2005 liability on line line 28 Lower Tax Liabilities Nonfinancial services nontax characteristics Number Percentage Number operating loss percent of USCCs percentage estimates Percentage Number Percentage percentage of corporations Percentage of FCDCs percentage of gross percentage of large percentage points receipts and assets reported no tax reported tax liabilities Return Line Item sampling errors statistically significant tax liability reported Tax Return Line Tax Years 1998 taxable income total income transfer pricing abuses U.S. corporation U.S. Income Tax U.S.-controlled corporations USCCs differed USCCs Large FCDCs USCCs reported USCCs That Reported Wholesale trade zero tax liability