The Taxation of Multinational Corporations - Tapa dura

The six papers in this vohune represent state-of-the-art empirical and conceptual research on various aspects of the taxation of multinational corporations. They were commissioned for and presented at a conference organized by Price Waterhouse LLP on behalf of the International Tax Policy Forum, held in Washington, DC in March, 1994. The ftrst four papers were originally published in the May, 1995 issue of International Tax and Public Finance. The Slemrod paper appeared in the Policy Watch Section of the November, 1995 issue of that journal. The foregoing papers were subject to the normal refereeing procedures of the journal, and the summaries that follow are drawn from there. The Leamer paper has not been previously published. Altshuler and Mintz examine one aspect of the 1986 u. s. Tax Reform Act --the change in the rules for the allocation of interest expense between domestic-(U. S. ) and foreign-source income. In the absence of rules, a parent with excess credits could reduce U. S. tax liability by allocating interest expense toward itself; thus reducing its taxable domestic income without any compensating increase in either the U. S. tax due on foreign-source income or the foreign tax due (which is independent of U. S. rules).

This volume presents state-of-the-art empirical and conceptual research on the taxation of multinational corporations. Topics include: rules for the allocation of interest expense between domestic (U.S.) and foreign-source income; compliance with the foreign tax provision of the U.S. tax code; an international comparison of the average effective rates of corporate taxation of multinationals; the effect of taxation on foreign direct investment; and international tax policy reviewed in parallel with the theory of international trade. This book will be of interest to public finance economists, international tax attorneys, and tax practitioners.