We study the relation between patent concentration and tax-motivated income shifting. Using affiliate-level data for European multinational corporations (MNCs) and employing the relative share of patents held by an MNC as a measure for patent concentration, we predict and find that tax-motivated...

This study creates and analyzes a model in which the income from intellectual property (IP) owned by a domestic parent and foreign subsidiary must be shared between the domestic and foreign countries for tax purposes. The model focuses on the effects of the commensurate with income standard,...

The article examines the problem of contributed zero-basis intangibles in light of the IRS’s inadvertent disclosure of a transaction structured by Bristol-Myers Squibb to shift billions of dollars of built-in gain to a related foreign partner