Over the years, many OECD countries, including the United States, have identified tax havens as a significant problem, and have acted to limit the ability of their taxpayers to use tax havens to reduce their taxes. The United States has implemented tax regimes, including subpart F and the...

In this paper, we discuss the hypothetical impact of the Amount A regime on US corporate income tax revenue. The general outline of the two-pillar taxation system, which includes Amount A as a part of Pillar One, was agreed upon in October 2021 by the Inclusive Framework delegates who tackled...

The Internal Revenue Code is riddled with features that allow U.S. taxpayers to reduce their federal tax liability by operating through tax haven companies. Some of these provisions are historic anomalies. Others are better understood as inadvertent loopholes than considered legislative grace....

The U.S. Supreme Court decision in the landmark 2018 Wayfair case greatly improved state governments' ability to enforce collection of sales taxes on a destination basis. This has reduced state tax competition with an essentially-untaxed internet, but has brought traditional cross-border...

This paper quantifies the unequal welfare effects of tax competition. I derive the optimal tax and transfer schedules in a free mobility union composed of countries that can either compete or set a uniform federal tax rate. In the absence of fiscal coordination, governments internalize that any...

This paper estimates the effect of profit shifting on corporate tax base erosion for the United States. Using Bureau of Economic Analysis survey data on U.S. multinational corporations over the period 1983 to 2012, the analysis estimates the sensitivity of foreign incomes to tax burdens for...

One of the signature achievements of the Base Erosion and Profit Shifting (BEPS) project is the collection of multinational company country by country data, for government use in tax enforcement efforts. In late 2019, the United States became the first country to release a complete set of these...

This paper analyzes the tax haven investment behavior of multinational firms from a country that exempts foreign income from taxation. High foreign tax rates generally encourage firms to invest in tax havens, though significant costs of reallocating taxable income dampen these incentives. The...

This paper analyzes the tax haven investment behavior of multinational firms from a country that exempts foreign income from taxation. High foreign tax rates generally encourage firms to invest in tax havens, though significant costs of reallocating taxable income dampen these incentives. The...

As a direct response to the recent trend in corporate expatriations, politicians have questioned the patriotism of firms that reorganize outside the U.S. and introduced numerous legislative proposals designed to prevent corporate expatriations. The implicit assumption made in proposing this...