Dyreng et al. (2017) find that the effective tax rates for both foreign and domestic corporations have steadily declined over the past quarter century. However, contrary to conventional wisdom, the authors also find that U.S. multinational corporations do not have a tax-based cost advantage...

More and more businesses, including partnerships, are awarding equity interests to valued employees to keep them. Partnerships often are unaware that even a small equity interest can stop the new partner from continuing to be treated as an employee for tax purposes. Failure to treat these...

We examine the effectiveness of four federal government actions, all of which were designed to curb the proliferation of corporate tax shelters dating back to the 1990s, at eliciting measurable changes in characteristics commonly associated with tax shelter firms. Our results suggest that the...

The term ‘‘carried interest'' is typically used to refer to profits interests issued by investment partnerships to their manager(s). It is an ownership interest in a partnership that has no liquidation value at grant, but entitles the holder to a share in future partnership profits, if any....

Firms that lobbied for the tax holiday for repatriations provided under the American Jobs Creations Act of 2004 were the largest beneficiaries of the provision. They repatriated an average of over $4 billion under the Jobs Act. Although firms that lobbied for the tax holiday repatriated large...

Recent theoretical research suggests that among U.S. firms that have reached their optimal level of investment in foreign operations some will be induced by the U.S. repatriation tax system to accumulate foreign earnings in foreign financial assets. In this paper we evaluate this behavior which...

Under the current U.S. tax system, corporations have an incentive to defer the repatriation of their foreign earnings. This incentive is commonly referred to as the lock-out effect. The lock-out effect is significant, as estimates indicate that U.S. corporations hold nearly $2 trillion of...