The income of Puerto Rican affiliates of U.S. corporations is essentially untaxed by either Puerto Rico or the U.S. This lowers the tax penalty on real investment there, and also makes it attractive to shift reported taxable income from the U.S. parent corporation to the Puerto Rican affiliate....

The income of Puerto Rican affiliates of U.S. corporations is essentially untaxed by either Puerto Rico or the United States. This lowers the tax penalty on investment there, and also makes it attractive to shift reported taxable income from the U.S. parent corporation to the Puerto Rican...

This analysis compares the current tax system with one that would exempt the foreign dividends of American corporations from U.S. taxes.

This paper uses data aggregated from tax returns of more than 500 U.S. multinational corporations (MNCs) to identify the role of host country tax rates in determining the amount of capital invested in 60 potential locations. The empirical results show that average effective tax rates have a...

This analysis of formula apportionment compared to the current U.S. system recognizes that income shifting has two main sources, excess returns attributable to intangibles and debt, and that a major goal of income division systems is preserving neutrality between arm’s length and related party...