Tax planning with intangibles has become one of the most popular and most vividly debated topics in international taxation. We incorporate various intellectual property (IP) tax planning models into forward-looking measures of effective tax rates, namely the disposal of intangibles to low-tax...

Using a survey of tax executives from multinational corporations, we document that some firms set their transfer pricing strategy to minimize tax payments, but more firms focus on tax compliance. We estimate that a firm focusing on minimizing taxes has a GAAP effective tax rate that is 6.6...

This paper examines the impact of Japan's 2009 adoption of a territorial tax regime using event study methods which leverage individual firm characteristics to identify underlying drivers of market reactions. Differences in Japanese firms' foreign and domestic effective tax rates yield an...

The Tax Cuts and Jobs Act (TCJA) of 2017 marked a significant change in U.S. domestic and international tax policy, altering incentives for U.S. firms to own foreign assets. We examine the initial response of U.S. firms’ foreign acquisition patterns to the TCJA’s key reform provisions. We...

Cederwall discusses the Tax Foundation's virtual colloquium, "Making Sense of Profit Shifting" — featuring 18 leading tax scholars, practitioners, and policy experts — and explains how it reveals six significant themes of incongruence in the understanding of profit shifting. Cederwall...

This chapter from a Practical Guide to Transfer Pricing (Lexis) compares the U.S. Section 482 transfer pricing regulations to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as revised in 2010. Section 482's purpose is to ensure that taxpayers subject...

The Two-Pillar Solution agreed by 137 countries on 8 October 2021 has been hailed as “historic” and a “a once-in-a-generation accomplishment for economic diplomacy.” To a significant extent, this is due to the expected impact of Pillar 2 (essentially a global minimum tax) on tax...

This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...

The costs of doing business internationally are many. Economizing on such costs is essential to be globally competitive. In this context, a rather overlooked area of cost reduction is the refund of global VAT incurred abroad on business expenses. A large number of exporters across the world do...

Finding common ground between corporate tax compliance and enforcement appears difficult and expensive, judging by the current inventory of almost $200 billion in proposed IRS transfer pricing tax adjustments, and projections of as much as $100 billion or more in annual U.S. federal corporate...