We develop a positive model of multinational firm behavior and analyze a firm’s incentive to transfer an intellectual property (IP) right of uncertain value offshore ex ante, i.e. before its success or failure is realized. With an asymmetric treatment of losses in the home country, the...

The purpose of the article is to check the impact of Net Operating Loss Policies (NOL) for firms. Net Operating Loss Policies (NOL) are a central fiscal tool because they enable firms to be taxed on their average profitability over time. A complete NOL policy has 4 dimensions: a NOL carryforward...

The purpose of the article is to check the impact of Net Operating Loss Policies (NOL) for firms. Net Operating Loss Policies (NOL) are a central fiscal tool because they enable firms to be taxed on their average profitability over time. A complete NOL policy has 4 dimensions: a NOL carryforward...

Under current U.S. tax law, a distinction is made between gains and losses by businesses. Losses that must be "carried forward" are subject to two penalties: a loss of interest, and expiration after fifteen years. Previous examinations have focused on the higher expected tax payments such a tax...

We develop a positive model of multinational firm behavior and analyze a firm’s incentive to transfer an intellectual property (IP) right of uncertain value offshore ex ante, i.e. before its success or failure is realized. With an asymmetric treatment of losses in the home country, the...

We develop a positive model of multinational firm behavior and analyze a firm's incentive to transfer an intellectual property (IP) right of uncertain value offshore ex ante, i.e. before its success or failure is realized. With an asymmetric treatment of losses in the home country, the...

This study investigates whether country risk factors, including political and fiscal budget risk, attenuate the effectiveness of tax policy tools that aim to encourage corporate risk-taking. Exploiting a cross-country panel, we predict and find that the effectiveness of loss offset rules and tax...

We develop a positive model of multinational firm behavior and analyze a firm's incentive to transfer an intellectual property (IP) right of uncertain value offshore ex ante, i.e. before its success or failure is realized. Our analysis highlights two major aspects of this decision. First, an...