We examine the effect of a permanent change to a country corporate income repatriation tax system on corporate financial policies. In 2009 Japan and the U.K. switched from a worldwide to a territorial system for the taxation of repatriated foreign earnings. The new system effectively reduces the...

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...