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.

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.

US trade policy is putting at risk the sustainability of the generic/biosimilar industry and the drug supply chain

2021 ◽  
pp. 174113432199431
Author(s):  
María Fabiana Jorge
Keyword(s):  
Supply Chain ◽  
Trade Policy ◽  
Pharmaceutical Products ◽  
Drug Supply ◽  
Active Pharmaceutical Ingredients ◽  
Pharmaceutical Ingredients ◽  
Us Trade Policy ◽  
Drug Supply Chain ◽  
Security Concern ◽  
The U.S

With the outbreak of the Coronavirus there is a new realization of the vulnerabilities of the U.S. drug supply chain. However, while such concerns may have been amplified by the pandemic, they preceded Covid-19 and were well documented before 2020. Indeed, in past years the U.S. Congress held several hearings addressing potential vulnerabilities in the U.S. drug supply chain, in part due to the increasing dependency on China as a dominant supplier of active pharmaceutical ingredients (APIs) and some finished pharmaceutical products. These vulnerabilities go well beyond health policy and constitute a national security concern. The article addresses how U.S. trade policy plays a significant role in shaping the pharmaceutical industry at home and abroad and is in part responsible for some of the current vulnerabilities of the U.S. drug supply chain.

Stimulus-Change Effects of Forcing in Alternation Behavior

1966 ◽  
Vol 19 (2) ◽  
pp. 515-518 ◽  
Author(s):  
R. N. Hughes
Keyword(s):  
Free Choice ◽  
Stimulus Change ◽  
Lower Degree ◽  
Alternation Behavior ◽  
Subsequent Removal ◽  
Transparent Barrier ◽  
Initial Attraction ◽  
High Degree

To test the hypothesis that forcing left or right in a T-maze produces more alternation because of the stimulus-change resulting from subsequent removal of the arm barrier, rats were given free-choice trials and forced trials with a wooden barrier (favouring a high degree of change) and with a transparent barrier (favouring a lower degree of change). Although alternation was unaffected by the three conditions, the percentage of first investigatory responses directed toward the alternate arm on Trial 2 was highest following forcing with the wooden barrier. It was concluded that a stimulus-change explanation for the effects of forcing was acceptable if these first investigatory responses were acknowledged as indices of initial attraction of attention by an arm.

scholarly journals Chain Reaction

2018 ◽  
Vol 140 (10) ◽  
pp. 30-35 ◽  
Author(s):  
Alan S. Brown
Keyword(s):  
Supply Chain ◽  
Additive Manufacturing ◽  
Supply Chains ◽  
Medical Devices ◽  
Business Models ◽  
Rolling Stock ◽  
Industrial Equipment ◽  
Special Report ◽  
Chain Reaction ◽  
The U.S

For 30 years, additive manufacturing has made all sorts of promises. Yet machines remained slow, materials expensive, and printers too inconsistent for critical parts. And additive was costly. Today, however, the technology is turning that past on its head. While additive manufacturing is usually the most expensive way to make any part, it makes economic sense for supply chains. Which is why manufacturers of everything from aircraft and rolling stock to appliances, industrial equipment, and medical devices are looking at 3-D supply chain solutions—as are the U.S. Marines and UPS. This special report looks at how additive manufacturing is disrupting business models and transforming supply chains.

Developing and Implementing a Port Fluidity Performance Measurement Methodology using Automatic Identification System Data

2018 ◽  
Vol 2672 (11) ◽  
pp. 30-40 ◽  
Author(s):  
C. James Kruse ◽  
Kenneth N. Mitchell ◽  
Patricia K. DiJoseph ◽  
Dong Hun Kang ◽  
David L. Schrank ◽  
...  
Keyword(s):  
Supply Chain ◽  
Travel Time ◽  
Performance Measures ◽  
Automatic Identification ◽  
Identification System ◽  
Army Corps ◽  
Supply Chain Performance ◽  
Travel Time Reliability ◽  
Automatic Identification System ◽  
The U.S

The U.S. Army Corps of Engineers (USACE) is responsible for the maintenance of federally authorized navigation channels and associated infrastructure. As such, USACE requires objective performance measures for determining the level of service being provided by the hundreds of maintained navigation projects nationwide. To this end, the U.S. Army Engineer Research and Development Center partnered with Texas A&M Transportation Institute to develop a freight fluidity assessment framework for coastal ports. The goal was to use archival automatic identification system (AIS) data to develop and demonstrate how ports can be objectively compared in relation to fluidity, or the turnaround time reliability of oceangoing vessels. The framework allows USACE to evaluate maintained navigation project conditions alongside port system performance indices, thereby providing insight into questions of required maintained channel dimensions. The freight fluidity concept focuses on supply chain performance measures such as travel time reliability and end-to-end shipping costs. Although there are numerous research efforts underway to implement freight fluidity, this is the first known application to U.S. ports. This paper covers AIS data inputs, quality control, and performance measures development, and also provides a demonstration application of the methodology at the Port of Mobile, Alabama, highlighting travel time and travel time reliability operating statistics for the overall port area. This work provides foundational knowledge to practitioners and port stakeholders looking to improve supply chain performance and is also valuable for researchers interested in the development and application of multimodal freight fluidity performance measures.

scholarly journals Learning from Past Policy: Assessing United States Foreign Policy over Indonesia in Resolving the 1999 East Timor Crisis

2021 ◽  
Vol 23 (1) ◽  
pp. 1
Author(s):  
Sigit S. Nugroho
Keyword(s):  
United States ◽  
Foreign Policy ◽  
Low Cost ◽  
The United States ◽  
East Timor ◽  
United States Foreign Policy ◽  
Case Study Analysis ◽  
High Degree ◽  
The U.S

Assessing the output of past foreign policy is instrumental for any country to learn policy-relevant insights, to appreciate its experience, and to improve its future conduct. To glean such insights, this article borrows Baldwin’s framework in assessing the success and failure in foreign policy. Using a case study analysis, it assesses the United States’ (U.S.) influence attempt towards Indonesia to resolve the 1999 East Timor humanitarian crisis. President Clinton’s decision to undergo an influence attempt primarily aimed to change Indonesia’s policy while gaining support from U.S. allies in the process. The article finds that Clinton’s decision was a highly successful attempt. This finding is based on several factors: (1) the attempt effectively attained the intended primary and secondary goals at a considerably high degree; (2) it was conducted at a considerably low cost for the U.S.; (3) it inflicted a high cost towards Indonesia; (4) the increase in Clinton’s stake strengthened the U.S. resolve to pursue the influence attempt; and (5) Clinton had successfully overcome the difficult undertaking as Indonesia possessed higher stake over East Timor. These findings provide some lessons for both U.S. and Indonesian foreign policymakers to chart future relations for the two nations.

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