In this report, I argue that the inversion situation is more nuanced, complex, and ambiguous than Edward D. Kleinbard acknowledges, and I challenge Kleinbard's claim that U.S. multinationals are on a tax par with their foreign competitors

For decades now, corporate inversions have been the topic of an ongoing debate between legislators, practitioners, and academics. Since the first inversion in 1982, while often arguing on the right methods, policy, and ways, Congress, the U.S. Department of the Treasury (“Treasury”), and...

The international corporate tax system is considered as a network and, just like for transportation, ‘shortest' paths are computed, minimizing tax payments for multinational enterprises when repatriating profits. We include corporate income tax rates, withholding taxes on dividends, double tax...

Multinational firms have been accused by politicians, regulators, and citizen groups of shifting profits to low-tax geographic areas. We present evidence that multinational firms with tax-haven operations tend to aggregate their geographic disclosures to a greater extent. The results are...

This chapter provides a survey of issues which emerge with the taxation of multinational enterprises. It addresses tax rates which affect multinational firms directly and focuses on provisions and incentives which relate to the profits and investments of such firms directly. It survey positive...

This paper investigates the costs and benefits of concluding double tax treaties with investment hubs. Based on a sample of 41 African economies from 1985-2015, the results suggest that signing treaties with investment hubs is not associated with additional investments; yet, these treaties tend...

An advance pricing agreement (APA) is a formal arrangement between a tax authority and a multinational enterprise (MNE) in which the parties jointly agree on the MNE's transfer pricing methodology, estimated taxable income and tax payments for a fixed period, thus reducing the likelihood of an...

We study the economic effects of unilateral adoption of corporate tax policies that include destination-based taxes and/or cash ow taxes in a heterogeneous agent model in which multinational firms can endogenously shift income between countries using transfer prices. Standard pass through...

The “fair” taxation of digital business models is challenging. One of the key aspects — both policy makers and the public opinion consider as most pressuring — is the determination of intragroup transfer prices for intangibles used in digital business models. In this paper, we address...

This paper examines if, when, and to what extent international income shifting incentives explain where multinational firms move offshored U.S. jobs. Using a small, detailed sample of offshored jobs from a program within the Department of Labor called Trade Adjustment Assistance (TAA), I find...