The Taxation of Multinational Corporations
Springer Netherlands, Jul 31, 1996 - Business & Economics - 158 pages
The six papers in this vohune represent state-of-the-art empirical and conceptual research on various aspects of the taxation of multinational corporations. They were commissioned for and presented at a conference organized by Price Waterhouse LLP on behalf of the International Tax Policy Forum, held in Washington, DC in March, 1994. The ftrst four papers were originally published in the May, 1995 issue of International Tax and Public Finance. The Slemrod paper appeared in the Policy Watch Section of the November, 1995 issue of that journal. The foregoing papers were subject to the normal refereeing procedures of the journal, and the summaries that follow are drawn from there. The Leamer paper has not been previously published. Altshuler and Mintz examine one aspect of the 1986 u. s. Tax Reform Act --the change in the rules for the allocation of interest expense between domestic-(U. S. ) and foreign-source income. In the absence of rules, a parent with excess credits could reduce U. S. tax liability by allocating interest expense toward itself; thus reducing its taxable domestic income without any compensating increase in either the U. S. tax due on foreign-source income or the foreign tax due (which is independent of U. S. rules).
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abroad accounting affiliates allocation alternative amount assets assumed average billion Canada coefficients companies compared compliance costs consistent corporate tax cost of capital countries debt deductions dependent determined differences Direct Investment domestic domestic investment domiciled earnings economic effective tax rates equal equity estimate evidence excess exports Figure firms flows foreign tax credit foreign-source income Fortune 500 free trade Global higher impact important included income taxes increase industry integration interest expense interest-allocation rules investment issues Italy Japan Japanese limitation lower manufacturing marginal mean measures Mexican Mexico Note Number operations paid parent percent position Price production question ratio reduce reform regression relative residence rules sample sector shareholders significant statement subsidiary suggest survey Table tax policy tax system taxation tion transfer U.S. multinationals U.S. tax United Kingdom variable worldwide