This paper studies how the global minimum tax shapes national tax policies and welfare in a formal model of international tax competition with heterogeneous countries. The net welfare effect is generally ambiguous from the perspective of non-havens. On the one hand, the global minimum tax raises...

The recent international agreement on a minimum effective corporate tax rate marks a profound change in global tax arrangements. The appropriate level of that minimum, however, has been, and remains, extremely contentious. This paper explores the strategic responses to a minimum tax, which the...

We study the aggregate and distributional consequences of replacing corporate profit taxes with shareholder taxes, namely taxes on dividends and capital gains, in a setting with incomplete markets and heterogeneity at both the household and the firm level. The reform yields distributional gains...

This paper uses micro data from country-by-country reporting of more than 3600 large multinational companies operating in 238 jurisdictions to analyze global profit shifting to avoid taxes. These companies report 7% of their global profits in jurisdictions with effective average tax rates below...

This paper examines the profit-shifting behaviour of emerging multinational firms from India. It is found that the before-tax profitability of subsidiaries differs according to whether they were established directly or via an Offshore Financial Centre (OFC). The impact of the corporate tax rate...

Illicit financial flows directly impact a country's ability to raise, retain, and mobilize its own resources to finance sustainable development. Against a backdrop of a weak public financial position attributed to capital flight, tax avoidance, and dependence on corporate income taxes,...

This paper estimates the causal effect of corporate tax hikes on firm investment based on more than 1,400 local tax changes. By observing planned and realized investment volumes in a representative sample of German manufacturing firms, we can study how tax hikes induce firms to revise their...

The aim of this study is to review the level of debt and the impact of taxation on the capital structure of companies operating within national and multinational corporate groups in the countries of the Visegrad Group. In the research, financial data was used from 2012-2018 regarding entities...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The explosion of profit shifting observed since the 1990s has resulted in hundreds of billions of dollars of tax revenues being lost around the world each year -...

There has been a pronounced change in the formulas states use to apportion the income of multistate corporations from one that placed equal weight on payroll, profits, and sales to one that places at least half the weight on sales, and eight base apportionment solely on sales. This paper, which...

This paper examines how corporate taxation of multijurisdictional firms using formula apportionment affects the incentives faced by individual firms and individual states. We find that formula apportionment creates factor price distortions which vary in general among firms within a state, and in...

The paper discusses the effects of the corporate tax on local R&D expenditures by multinational enterprises (MNEs) when income from intellectual property (IP) may or may not benefit from a special IP regime. Our model shows that an increase of the standard corporate tax may have positive effects...

This paper examines the effects of the 2017 U.S. tax reform, commonly known as the ‘Tax Cuts and Jobs Act’ [TCJA] on cross-border M&As of U.S. acquirers. The TCJA replaced the U.S. worldwide tax system by a territorial system, albeit with one important exception: the ‘Global Intangible...

This is a response to Professor Avi-Yonah's paper on a "New Corporate Tax" (2021). This paper's aim is to discuss the justifications and aims of a corporate tax and corporate tax policy. Specifically, this paper seeks to understand Avi-Yonah's proposal of a graduated system for the corporate...

This paper examines the intertemporal effect of corporate income taxation on the investment behavior of a firm that faces imperfect capital markets. It shows that when capital markets are imperfect, the optimizing firm goes through different phases of growth. In this dynamic setting, the effect...

The desirability of doing business in any foreign country may turn on the ability to avoid double taxation. This issue is a serious concern for foreign countries. For example, in China authorities have expressed a willingness to pursue a treaty specifically removing the problem of double...

Integration of the corporate and individual income taxes can be achieved by providing shareholders a credit for corporate taxes paid with respect to corporate earnings distributed as dividends. When such integration was previously considered in the U.S., proponents emphasized that it could...

The use of third party and related party interest is one of the profit-shifting techniques available in international tax planning. The fluidity and fungibility of money make it a relatively simple exercise to adjust the mix of debt and equity in a controlled company. When the level of debt...

This study examines the effect of shareholder taxes on bank risk-taking. Economic theory predicts that personal tax rates affect individual risk-taking through risk-sharing with the government via full loss offsets. Exploiting the passive activity loss limitations and detailed ownership data for...

This paper examines the asset write-off behavior of loss firms in response to tax rule changes. In particular, we investigate two simultaneous changes in tax loss carryforward offsetting in opposite directions in Germany and France. Understanding if and how tax losses affect firms’ financial...

This Article argues that a deduction for state income taxes, paid to a sister state violates the normative principles of income taxation by allowing a cost of generating tax-exempt income. Forty-five states and the District of Columbia tax corporations on their net income, and forty percent of...

Corporation tax is an inefficient way to raise state revenue. It has a negative impact on growth, investment, and entrepreneurship. A 2014 review of the literature found that 57.6% of the amount raised by corporation tax is born by workers. Since 1981, the average corporate tax rate in key OECD...

Taxes are acknowledged by the United Nations to play a vital role in achieving the Sustainable Development Goals, while, according to the World Economic Forum, stakeholders’ increasing interest in societal impact and greater demand for transparency are encouraging firms to go beyond simply...

This paper presents a method of studying the distributional consequences of corporate tax changes by imputing to individual tax returns the net effect of changes in effective corporate tax rates. Particular attention is given to the difference between nominal and real capital income, to the...

To study the effects of 'double taxation' (first at the corporation level, then at the shareholder level this paper analyzes a model with a tax on all corporate distributions to equity owners and no other taxes. Contrary to the common view, the tax is shown to have no substitution effect and, in...

In 1990, the government of Sweden introduced a major tax reform to take effect in 1991. The Swedish system prior to the legislation was so complex that the size and magnitude of the likely effects of the reform on incentives to invest were unknown. In this paper, we draw on Södersten (1989) and...

This study examines the effect of shareholder scrutiny of tax issues on corporate tax behavior. Specifically, we examine the factors associated with receiving shareholder tax litigation and the effect of such litigation on the future tax behavior of both the sued firm and its peers. We find...

In this paper we develop some simple models of optimal tax and tariff policy in the presence of global corporations that operate in an imperfectly competitive environment. The models emphasize two important differences in the practical application of tax and tariff policy - tax, but not tariff,...

An important deficiency in Harberger's (1962) model of corporate income taxation is its inability to consider both corporate and noncorporate production of the same good. This precludes analysis of within-industry substitution of noncorporate for corporate production in response to the tax. Such...

This paper studies the interaction between the federal and state tax systems during the 1980s and in particular considers how the Tax Reform Act of 1986 affected state tax structure. Using a panel data set on state governments over a nine year period, I estimate tax share equations for six...

Two well-noted phenomena of recent decades are the increasing concentration of personal income and the declining rate of corporate profitability. This paper investigates to what extent these two trends have a common explanation extent these two trends have a common explanation-shifting of income...

We study the choice between source-based and destination-based corporate taxes in a two-country model, allowing multinational firms to use transfer pricing to allocate profits across tax jurisdictions. We show that source-based taxation is a Nash equilibrium for tax revenue maximizing...

This paper investigates how corporate income taxes affect international trade, and identifies the underlying channel. Using data on 33 NACE sectors, for 34 EU and OECD economies, over the period 2005-2014, we find that corporate income taxes reduce exports and imports only when the stock of...

The Global Formulary Apportionment Model (GFA Model) applies to the tax accounting of the Global Taxable Income (GTI) of a Multinational Enterprise (MNE) and the Formulary Apportionment (FA) of this GTI between the member states of the model – here the G 20 nations. The resulting Global...

Incorporating the firm’s corporate parent in a tax haven is a major decision that receives significant attention from many stakeholders, yet certain implications of this corporate strategy remain unclear. While tax haven incorporation offers tax savings, it also imposes risks that are...

While there have been few decided cases under the 1995 Transfer Pricing regulations and the OECD Guidelines, it is clear by now that the transfer pricing problem is as bad as it ever was. That is why my co-authors Kimberly Clausing and Michael Durst and I have recently re-proposed adopting...

A recurring theme in the literature on taxation has been uncertainty about the incidence of the corporate income tax. The answer may be even more elusive for state taxes than for federal taxes. As seen by one state, a cor- porate income tax levied on the basis of formula apportionment of total...

What are the macroeconomic implications of re-allocating taxing rights away from source countries (where goods are produced) to market countries (where goods are consumed) and introducing minimum rates in international profit taxation? We assess this question in a dynamic macroeconomic model...