The service provided by financial institutions such as banks is described as an "intermediary service", linking depositors with money to lend and borrowers seeking loan funds. Banks collect a fee for these services through the spread on interest they pay to depositors and charge to borrowers. At...

We address two issues: 1. Do dividends from foreign subsidiaries depend on the residual home country tax, and can this be reconciled with existing models? The evidence seems to be inconsistent with both the Hartman-Sinn ‘New View’ and the Weichenreider and Altshuler-Grubert repatriation...

Since 1996 the foreign share of U.S. multinational corporations’ worldwide income has risen sharply. For example, in a sample of large nonfinancial MNCs, the aggregate foreign share increased from 37.1 percent in 1996 to 51.1 percent in 2004. This increase is decomposed into its major sources,...

This analysis of formula apportionment compared to the current system is based on the observation that income shifting has two sources, intangible income and debt. The analysis also recognizes that a major goal of the transfer pricing or income allocation system is to preserve the tax neutrality...