We use data from the U.S. Treasury corporate tax files for 1984 and 1992 to address two related questions concerning the investment decisions of U.S. multinational corporations. First, how sensitive are investment location decisions to tax rate differences across countries? And second, have...

The 2017 US tax legislation - widely referred to as the Tax Cut and Jobs Act (TCJA) - fundamentally transformed the US system of international taxation. It ostensibly ended worldwide taxation but introduced, for instance, a new tax on "Global Intangible Low-Taxed Income" (GILTI). This paper...

The United States has policed the multinational effects of multinational corporations more aggressively than any other coun-try, but recent decisions under the Alien Tort Statute indicate that it is now backtracking. Europe, paradoxically, is moving in the other direction. Why do some countries...

This paper assesses the impacts of the 2017 tax reform act on U.S. competitiveness in terms of changes in incentives for U.S. domestic corporate investment and the taxation of U.S.-headquartered companies and their foreign subsidiaries relative to foreign-headquartered companies. The reduction...

This paper examines the effects of state corporate income taxes on the location of foreign direct investment, taking into account the state governments' behavior when setting taxes. Ignoring the tax setting behavior of states may bias the estimate of the tax effects on foreign direct investment....

The Tax Cuts and Jobs Act of 2017 (TCJA) eliminated disincentives for U.S. multinational corporations (MNCs) to repatriate foreign subsidiaries' earnings, but the TCJA included additional provisions that will impact U.S. firms' acquisition decisions. We find that both the likelihood and number...

We estimate a dynamic model, featuring agency conflicts and a stochastic tax reform arrival, to evaluate how the change from a worldwide to territorial tax system, enacted under the TCJA, affects foreign investment. Although a worldwide system imposes a higher tax liability on foreign income, we...

This paper sets forth a simple, but potentially infinitely expandable, model through which the consequences of changes in U.S. international tax rules can be explored. The question it poses is straightforward: Assume that our task is to aggregate funds from taxable U.S. or foreign individual...

Prior research has documented a substantial “lockout” effect resulting from the current U.S. worldwide tax and financial reporting systems. We hypothesize that foreign firms are tax- favored acquirers because they can avoid the U.S. tax on repatriations. Consistent with this tax advantage,...

In 2009, Japan began to exempt dividends paid by Japanese-owned foreign subsidiaries to their parent firms from home-country taxation. This tax reform switched Japan's corporate tax system to a territorial tax system that exempts foreign income from home-country taxation. In this paper, I...