Does Withholding Tax Reduce International Income-Shifting by FDI?

2021 ◽  
pp. 25-41
Author(s):  
Anna Białek-Jaworska
Keyword(s):  
Income Shifting ◽  
Withholding Tax

Income Shifting by NOL Firms When Loss Carry-Forward Period is Extended

2019 ◽  
Vol 44 (1) ◽  
pp. 39-70
Author(s):  
Hee-Yeon Sunwoo ◽  
Woon-Oh Jung
Keyword(s):  
Income Shifting

A Model of Multinational Income Shifting and an Application to Tax Planning with E-Commerce

2014 ◽  
Vol 36 (2) ◽  
pp. 27-53 ◽  
Author(s):  
Kenneth J. Klassen ◽  
Stacie K. Laplante ◽  
Carla Carnaghan
Keyword(s):  
Tax Planning ◽  
Investment Model ◽  
Income Shifting ◽  
Tax Rates ◽  
Foreign Investments ◽  
Effective Tax Rates ◽  
Tax Rate ◽  
Foreign Earnings ◽  
Joint Consideration ◽  
The U.S

ABSTRACT: This manuscript develops an investment model that incorporates the joint consideration of income shifting by multinational parents to or from a foreign subsidiary and the decision to repatriate or reinvest foreign earnings. The model demonstrates that, while there is always an incentive to shift income into the U.S. from high-foreign-tax-rate subsidiaries, income shifting out of the U.S. to low-tax-rate countries occurs only under certain conditions. The model explicitly shows how the firms' required rate of return for foreign investments affects both repatriation and income shifting decisions. We show how the model can be used to refine extant research. We then apply it to a novel setting—using e-commerce for tax planning. We find firms in manufacturing industries with high levels of e-commerce have economically significant lower cash effective tax rates. This effect is magnified for firms that are less likely to have taxable repatriations. JEL Classifications: G38, H25, H32, M41.

Security Analyst and Stock Market Efficiency in Anticipating Tax-Motivated Income Shifting

2006 ◽  
Vol 81 (1) ◽  
pp. 227-250 ◽  
Author(s):  
Philip B. Shane ◽  
Toby Stock
Keyword(s):  
Earnings Forecasts ◽  
Income Shifting ◽  
Market Prices ◽  
Tax Rate ◽  
Income Effects ◽  
Market Participants ◽  
Security Analyst ◽  
Market Inefficiency ◽  
Reported Earnings ◽  
Statutory Tax Rate

In the context of the statutory tax rate reductions enacted in the Tax Reform Act of 1986, this paper investigates the degree to which capital market participants anticipate and correctly interpret temporary income effects of tax-motivated income shifting. We find evidence consistent with financial analysts' earnings forecasts failing to anticipate earnings management that shifts income from fourth quarters in higher tax rate years to immediately following first quarters of lower tax rate years. The evidence suggests that this failure is not the result of a decision to ignore the income shifting, but rather an inability to recognize temporary components of reported earnings. We also find evidence that market prices do not fully reflect the temporary income effects of tax-motivated income shifting, and that analyst inefficiency explains about half of the market inefficiency. We interpret these inefficiencies as potentially important costs of tax planning that could limit the ability of public firm managers to implement otherwise optimal tax strategies.

scholarly journals Managing the Dollar Over Its Cycles

2021 ◽  
Author(s):  
Lawrence L. Kreicher ◽  
Robert N. McCauley
Keyword(s):  
Foreign Exchange ◽  
Foreign Exchange Market ◽  
Private Investment ◽  
The United States ◽  
Exchange Market ◽  
Foreign Exchange Intervention ◽  
Traded Goods ◽  
Service Production ◽  
Withholding Tax ◽  
The U.S

AbstractThe United States has ceded to the rest of the world managing the dollar’s value. For a generation, the U.S. authorities have all but withdrawn from the foreign exchange market. Yet the dollar does not float freely as a result of this hands-off U.S. policy. Instead, other authorities manage the dollar exchange rates, albeit separately. These authorities make heavier purchases of dollars in its downswings than in the upswings, damping its decline. Thus, the Fed finds that accommodative monetary policy transmits less to U.S. manufacturing and traded services, and relies on still lower rates to stimulate interest-sensitive housing and auto demand. The current U.S. dollar policy of naming and shaming surplus-running countries accumulating foreign exchange reserves does not seem to work. Three alternatives warrant consideration. First, the U.S. could reinstate its withholding tax on interest income received by non-residents and even add policy criteria to bilateral tax treaties. Second, the U.S. authorities could retaliate by selling dollars against the currencies of dollar-buying jurisdictions running chronic surpluses. However, either the withholding tax or such retaliatory foreign exchange intervention pose huge practical challenges. Third, the U.S. authorities could re-enter the foreign exchange market, making large-scale asset purchases in foreign currency when the dollar rises sharply against its average value. Such a policy would encourage private investment in U.S. traded goods and service production. The challenge is to set ex ante foreign exchange intervention rules to guide market participants’ expectations, even positioning them to do the authorities’ work.

To Shift or Not To Shift? Intertemporal Income Shifting as a Response to the Risk Capital Allowance Introduction in Belgium

2016 ◽  
Vol 26 (3) ◽  
pp. 531-559 ◽  
Author(s):  
Kathleen Andries ◽  
Martine Cools ◽  
Steve Van Uytbergen
Keyword(s):  
Income Shifting ◽  
Risk Capital

Foreign Employment, Income Shifting, and Tax Uncertainty

2021 ◽  
Author(s):  
Katharine D. Drake ◽  
Nathan C. Goldman ◽  
Frank Murphy
Keyword(s):  
Supply Chain ◽  
Selection Bias ◽  
Lower Degree ◽  
Income Shifting ◽  
Costs And Benefits ◽  
High Degree ◽  
The U.S ◽  
Tax Uncertainty

We examine the effect of foreign employment on two outcomes-income shifting and the tax uncertainty of foreign transactions. Using a hand-collected sample of employment disclosures, we partition our sample into firm-years with a higher or lower degree of foreign employment. Using two distinct income shifting models, we document that, on average, a high degree of foreign employment is associated with greater tax-motivated income shifting out of the U.S. We also posit and find that a high degree of foreign employment enhances the economic substance of foreign transactions, reducing the tax uncertainty associated with foreign income. We conduct additional analyses to mitigate selection bias concerns, and we use exogenous changes to the costs and benefits of income shifting using foreign employment to strengthen identification. Our results highlight firms' use of employees as part of a tax-efficient supply chain and how foreign employment enhances income shifting opportunities between jurisdictions.

Sign in / Sign up

Export Citation Format

Share Document