This paper analyzes the effect of and performance of foreign direct investment (FDI). sparing foreign investment income to permit investors to receive the full benefits of host country tax reductions. For example, Japanese firms investing in countries with whom Japan has agreements are entitled...

This paper reviews quantitative studies of the impact of international tax rules on the financial and real behavior of multinational firms. The evidence, much of it recent, indicates that taxation significantly influences foreign direct investment, corporate borrowing, transfer pricing, dividend...

This paper explores the normative theory of international taxation by recasting it in parallel with the theory of international trade. It first sets out a definition of 'free trade taxation,' first in the global context and then in the unilateral context. It then evaluates against this standard...

This paper investigates how the tax system of the U.S. and the capital-exporting country combine to affect the flow of foreign direct investment (FDI) into the U.S. First, using aggregate data, it corroborates earlier work suggesting that the U.S. effective tax rate does influence the amount of...

Estimating the causal effect of offshoring on domestic employment is difficult because of the inherent simultaneity of multinational firms' domestic and foreign affiliate employment decisions. In this paper, we resolve this identification problem using variation in Bilateral Tax Treaties (BTTs),...

This paper investigates how the tax system of the U.S. and the capital-exporting country combine to affect the flow of foreign direct investment (FDI) into the U.S. First, using aggregate data, it corroborates earlier work suggesting that the U.S. effective tax rate does influence the amount of...

In this article, the author reviews the major international tax policy developments of 2018 and assesses the progress of initiatives to tackle base erosion and profit shifting in both the developed and developing worlds

The enactment of the so-called Tax Cuts and Jobs Act of 2017 (TCJA) significantly changes the landscape for tax planning and compliance by U.S. multinational corporations (MNCs). The promised shift to a more territorial system actually results in a greater likelihood that more of a U.S. MNC's...

Developing countries frequently grant corporate income tax incentives to attract foreign direct investment that would ultimately contribute to their economic growth. To secure the effectiveness of these measures at a cross-border level in the context of jurisdictions that eliminate double...

The new Tax Cuts and Jobs Act repeals approximately one-third of the foreign tax credit system. (The foreign tax credit generally reduces U.S. tax by the amount of the U.S. taxpayer's foreign income taxes, subject to many requirements.) Essentially, partial repeal will make it much harder to...