Studies in International Taxation - Alberto Giovannini - Bog

As the global economy continues to evolve, events such as the unification of European markets have prompted economists and policymakers to consider whether the current system of taxing income is inconsistent with the trend toward liberalized world financial flows and increased international competition. To help assess the effectiveness of existing tax policies and incentives, this volume presents new research on how taxes affect the investment and financing decisions of multinationals today. The authors examine international financial management, business investment, and international income shifting. The first three papers focus on financial management. Chapter 1 analyzes how tax and non-tax factors affect the relative importance of portfolio equity investments versus foreign direct investments and finds that the composition of equity flows differs dramatically according to tax differences. The authors of the second chapter look at the impact of U.S. and Canadian tax reforms on the financing of U.S. multinationals operating in Canada. Chapter 3 uses new data from 1986 corporate income tax returns to examine the effects of taxes on decisions by foreign subsidiaries to repatriate dividends to U.S. parent corporations. The next three chapters address international business investment. The authors of Chapter 4 consider why most models fail to show how tax policy affects foreign direct investment, and they offer improved models. Chapter 5 models U.S. tax incentives for the level and location of R&D performed by multinationals, and reveals that changes in the after-tax price of R&D have a significant effect on spending decisions of U.S. multinationals. Chapter 6 offers descriptive evidencefrom a careful field study of location and sourcing decisions in nine U.S. multinational manufacturing corporations. The final two papers examine income shifting. In chapter 7, the authors consider the fact that foreign-controlled companies in the United States pay lower taxes than do domestically-controlled companies. Unlike other studies, this one uses firm-level data files, including the actual tax returns filed by foreign-controlled companies. The eighth paper quantitatively assesses the importance of income shifting of U.S. multinationals, using Compustat data for 1984 through 1988 as well as information from annual reports. This volume will guide the development of new theoretical models in public finance and international economics, as well as inform the ongoing policy debate about reforming the taxation of multinational businesses in the United States and abroad.